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1. 88 FR 82796 — Long-Term, Part-Time Employee Rules for Cash or Deferred Arrangements Under Section 401(k)
   IRCProposed Rules (FR)Proposed Nov 27, 2023
   …d the IRS released Notice 2020-68, 2020-38 IRB 567, which includes guidance with respect to section 112 of the SECURE Act. Q&A C-1 of Notice 2020-68 explains that, although section 112(b) of the SECURE Act excludes 12-month periods beginning before January 1, 2021, for purposes of determining an employee's eligibility …
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003related by meaning
   foregoing statutory - 19 - requirements were satisfied for the audit year. Therefore, we reject petitioner’s claim, raised at trial, to deductions for three dependency exemptions. VI. Respondent’s Section 72(t) Determination Section 72(t) provides, in pertinent part, as follows: SEC. 72(t). 10-Percent Additional Tax on…
4. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
   IRCCourt RulingsFeb 22, 1999★ strong match
   112 T.C. No. 6 UNITED STATES TAX COURT GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18999-97. Filed February 22, 1999. H and W, who were both disqualified persons within the meaning of sec. 4975, I.R.C., borrowed $340,000 from the qualified pension plan…
5. Treas. Reg. § 1.72-9 — Tables.
   IRCRegulationsJul 26, 2016
   …2.6 2.4 2.3 110 3.8 3.6 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Surviv…
6. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
   IRCCourt RulingsAug 24, 1995related by meaning
   OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
7. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
   IRCCourt RulingsMar 12, 2008
   …70 271,94 1 5 271,941 25,000 246,941 20,755 267,69 6 6 267,696 25,000 242,696 20,416 263,11 2 7 263,112 25,000 238,112 20,049 258,16 1 8 258,161 25,000 233,161 19,653 252,81 4 9 252,814 25,000 227,814 19,225 247,03 9 10 247,039 25,000 222,039 18,763 240,80 2 11 240,802 25,000 215,802 18,264 234,06 6 12 234,066 25,000 2…
8. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
   IRCCourt RulingsAug 6, 1991related by meaning
   f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
9. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
   IRCCourt RulingsJun 14, 1982related by meaning
   nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
10. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
11. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
12. Treas. Reg. § 54.4980H-1(a)(3) — Definitions.
    IRCRegulationsDec 30, 2016
    …ive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, Public Law 112-9 (125 Stat. 36 (2011)), the Department of Defense and Full-Year Continuing Appropriations Act, 2011, Public Law 112-10 (125 Stat. 38 (2011)), and the 3% Withholding Repeal and Job Creation Act, Public Law 112-56 (12…
13. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …34 2,234 --- Interest 3,109 3,109 3,109 --- Insurance 10,634 10,634 10,634 --- Commissions and fees 112,432 112,432 112,432 --- i. Other Expenses On brief respondent concedes that petitioners have substantiated all but $170 of this reported expense. After careful review of the record, we find that petitioners substanti…
14. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    of Pub. L. 104-106, 110 Stat. 521 (36 U.S.C. 5522); Sec. 890.112 also issued under section 1 of Pub. L. 110-279, 122 Stat. 2604 ( printed page 51769) (2 U.S.C. 2051); Sec. 890.113 also issued under section 1110 of Pub. L. 116-92, 133 Stat. 1198 (5 U.S.C. 8702 note); Sec. 890.301 also issued under section 311 of Pub. L…
15. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    … Plan The Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. No. 105-206, 112 Stat. 685, as pertinent to this case, added section 402(c)(4)(C). Section 402(c) provides general rules applicable to rollovers from exempt trusts. Section 402(c)(4) defines the term "eligible rollover distribution".…
16. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …"-0-". - 9 - [*9] 1994 23,331 -01995 25,885 -01996 1 26,500 -01997 26,500 -01998 i 26,500 -01999 26,112 3,112 2000 J 25,072 19,669 2001 25,011 26,000 2002 } 129,030 130,000 Total 512,985 315,699 The corporation did not begin to cover its expenses and was losing money until the Fletchers had owned it for 18 months. The …
17. T.C. Memo. 2006-106 — Susan F. Mostafa v. Commissioner
    IRCCourt RulingsMay 15, 2006
    …e's gross income as provided in section 72. Sec. 408(d)(1); Lemishow v. Commissioner, 110 T.C. 110, 112 (1998). However, "rollover contributions" are not includable in gross income. Sec. 408(d)(3); Lemishow v. Commissioner, supra at 112. To qualify as a rollover contribution, the.IRA distribution must be rolled over in…
18. 79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage
    IRCFinal Rules (FR)Feb 12, 2014
    …ive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, Public Law 112-9 (125 Stat. 36 (2011)), the Department of Defense and Full-Year Continuing Appropriations Act, 2011, Public Law 112-10 (125 Stat. 38 (2011)), and the 3% Withholding Repeal and Job Creation Act, Public Law 112-56 (12…
19. 78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage
    IRCProposed Rules (FR)Proposed Jan 2, 2013
    …ive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, Public Law 112-9 (125 Stat. 28, (2011)), the Department of Defense and Full-Year Continuing Appropriations Act, 2011, Public Law 112-10 (125 Stat. 38, (2011)), and the 3% Withholding Repeal and Job Creation Act, Public Law 112-56 (…
20. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
    IRCCourt RulingsOct 9, 2007related by meaning
    ers . In response to our leniency, petitioner once again ignored our Rules and our order . -5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a sanction pursuant to Rule 123(b) . See Stringer v . Commissioner , 84 T .C . 693, 704-705 (1985), affd . withou…