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86 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …es that BAI placed these assets in service before its 2003 tax year--the year BAI claimed a section 179 deduction for them. BAI's own records say the "Equipment--Krom." and the "Equipment--Henn." were placed in service after the start of its 2003 tax year. But BAI admitted on brief that "[t]he evidence shows that these…
  2. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    taxable income with pinpoint accuracy, the fact of the matter is that petitioners have no one to blame but themselves. Petitioners, each of whom is a well-educated professional, realized substantial amounts of income during the subject years and instead of timely reporting that income on Federal income tax Petitioners…
  3. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …ulgated, have a significant economic impact on a substantial number of small entities, section 603 [179]
  4. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …the selection of annuity providers under 29 CFR 2550.404a-4). Cf. McNeil v. Time Ins. Co., 205 F.3d 179, 190 (5th Cir. 2000) (“ERISA's section 505 granted the Secretary of Labor the authority to promulgate regulations for implementation of ERISA, and the Secretary has created an exemption for certain group or group-typ…
  5. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993
    3,179.00 does not qualify for the 10-year averaging method because you do not meet the requirements of section 402 of the Internal Revenue Code. * * * (b) It is determined that your tax on an IRA is $1,317.90 ($13,179.00 times 10 percent) in lieu of $1,377.90 as shown in your return.[] (c) It is determined that you are…
  6. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    and, therefore, there is a genuine dispute of material fact as to his deductible expenses sufficient to preclude entry of summary judgment. Discussion I. Relevant Legal Authorities A. Deficiency in Tax The Internal Revenue Code imposes a Federal income tax on the taxable income of every individual. See sec. 1. The taxa…
  7. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    IRCCourt RulingsNov 3, 2008
    …s actually rendered" .- tion 79 Expens e deduct as a current expense the imitations, of any section 179 d 8 - property that is used in an active trade or business and placed in service during the taxable year . Sec . 179(a), (b), (d)(1) ; see sec . 1 .179-4(a), Income Tax : Regs . ,The election must specifythe total se…
  8. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …h were to be sold and transferred to the petitioner, had a book value as of May 31, 1957, of $1,576,179.57. In accordance with the above-mentioned agreement of May 22, that the buyers were to pay $300,000 less than the book value of said assets, the total purchase price to be paid by Fohrman and Dorgan or their nominee…
  9. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  10. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020★ strong match
    …125,952 --- Utilities 5,239 5,239 5,239 --- Office expenses 3,060 3,060 3,060 --- Depreciation/sec. 179 expense 36,179 36,179 --- 36,179 Car and truck expenses 756 756 --- 756 Advertising 435 435 435 --- Repairs and maintenance 71 71 71 --- i. Wages On brief respondent concedes that petitioners have substantiated BJWre…
  11. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012related by meaning
    ed in section 274(d). Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); Rodriguez v. Commissioner, T.C. Memo. 2009-22 (the strict substantiation requirements of section 274(d) preclude the Court and taxpayers from approximating certain expenses). r - 12 - Petitioners' tabl…
  12. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    …uture enhancements 178 PART II. PROGRAM EFFECT AND ELIGIBILITY SECTION 3. EFFECT OF EPCRS; RELIANCE 179 .01 Effect of EPCRS on retirement plans 179 .02 Compliance statement 179 .03 Excise and other taxes 179 .04 Reliance 179 SECTION 4. PROGRAM ELIGIBILITY 179 .01 EPCRS Programs 179 .02 Effect of examination 180 .03 SCP…
  13. 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…
  14. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    …tions under § 414(h) 178 .07 Other limits on scope of determination letter 178 .08 Leased employees 179 .09 Partial terminations 179 .10 Publication 794, Favorable Determination Letter 179 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 179 .01 Scope 179 .02 Complete information required…
  15. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  16. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …31 19,545 10,562 -0- 10,562 1993 41,365 20,800 20,565 10,132 -0- 10,132 1992 39,908 20,800 19,108 9,179 -0- 9,179 1991 38,502 -0- 38,502 9,323 .-0- 9,323
  17. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  18. T.C. Memo. 1996-517 — Jeffery Allen Robinson v. Commissioner
    IRCCourt RulingsNov 25, 1996
    …nt allowed petitioner an additional withholding credit of $25 representing taxes withheld on the $1,179 unreported wage income. early distributions from qualified retirement plans under section 72(t). The issues for decision are: (1) Whether petitioner failed to report wage income of $1,179 in 1992; (2) whether petitio…
  19. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …an 178 .03 Timing of determination letter applications for adopting employers of pre-approved plans 179 SECTION 14.WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS? 179 .01 Scope 179 .02 Controlling member must accompany any multiple employer plan submission 179 .03 …
  20. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…