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59 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
  2. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    …ced prudential standards under section 165 of the Dodd-Frank Act. See Public Law 115-174, 132 Stat. 1296 (2018). The Board amended the scope of application of these requirements in October 2019.
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ccord Grajales, 156 T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68, Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional amount” within the meaning of section 6751(c). To implement the foregoing, An order will be issued g…
  4. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
  5. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ks to collect the 10-percent additional tax on early distributions from qualified retirement plans. Once again, other than his self-serving testimony, petitioner has offered no evidence in support of his position, no bank statements or other evidence that would corroborate his assertion that the tax was withheld or tha…
  6. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    …r, 69 T.C. 1055 (1978); Ellison v. Commissioner, 55 T.C. 142 (1970); James v. Commissioner, 25 T.C. 1296 (1956); Hand v. Commissioner, 16 T.C. 1410 (1951). A third and more applicable classification exists, that of officer. The Supreme Court recognized these three classifications in Metcalf & Eddy v. Mitchell, 269 U.S.…
  7. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …curacy - related penalties on the results of the parties’ Rule 155 computations) , aff’d , 990 F.3d 1296 (11th Cir. 2021) ; Bergquist v. Commissioner, 131 T.C. 8, 24, 25 (2008) (conditioning the application of substantial valuation misstatement accuracy-related penalties on the results of the parties’ Rule 155 computat…
  8. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  9. IRCCourt RulingsMar 30, 1978
    …profession naturally cause an employer’s control to be more general. James v. Commissioner, 25 T.C. 1296, 1301 (1956). The factual situation before us parallels that in James. We find that the principal had the right to control more than results.
  10. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    … T.C. 460 (2016); see also Clay v. Comm issioner, 152 T.C. 223, 246, 249 (2019), aff ’ d , 990 F.3d 1296 (11th Cir. 2021). We first address the proportionate increases to the accuracy - related penalties asserted by respondent in the Amended and Second Amended Answers. Respondent ’ s burden includes showing written sup…
  11. 34 T.C. 73 — Zeltzerman v. Commissioner
    IRCCourt RulingsApr 18, 1960
    …ration of all the facts and circumstances and is not free from doubt. Cf. Wendell E. James, 25 T.C. 1296. We find it unnecessary to decide that question, since even if we assume, arguendo, that the petitioner was an employee our conclusions on other aspects of the case preclude a holding in his favor.
  12. 83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCProposed Rules (FR)Proposed Dec 21, 2018
    …izations with less than $10 billion in total consolidated assets. See Public Law 115-174, 132 Stat. 1296 (2018). Back to Citation 13.
  13. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …, 154 T.C. 1, 14 – 15 (2020); Clay v. Commissioner , 152 T.C. 223, 248– 49 (2019), aff’d , 990 F.3d 1296 (11th Cir. 2021). Respondent produced a copy of the Civil Penalty Approval Form signed on May 22, 2009, by the immediate supervisor of R evenue A gent
  14. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    ollars, petitioner's persistence in pursuing a tax protest agenda is inexcusable'" and "A penalty in the maximum amount of $25,000 is appropriate when lesser amounts have not deterred a taxpayer's defiance of the tax laws and of the rulings of the courts." Id. (quoting January 11, 2008, order and order to show cause). …
  15. T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner
    IRCCourt RulingsJun 17, 1998
    …s. 33-741 to 33-749 (West 1990); see also Maciborski v. Chase Serv. Corp. , 161 Ariz. 557, 779 P.2d 1296, 1298-1299 (Ariz. Ct. App. 1989). 7 As indicated above, respondent's $1,360,724 valuation of the annuity is in accordance with the mandated standards of sec. 7520; that is, in valuing the annuity, respondent employe…
  16. IRCCourt RulingsJun 13, 1977
    …. 974, 984 (1975); Ellison v. Commissioner, 55 T.C. 142, 152 (1970); James v. Commissioner, 25 T.C. 1296, 1300 (1956); Hand v. Commissioner, 16 T.C. 1410, 1414 (1951). Section 31.3121(d)-l(c)(2), Employment Tax Regs., provides one definition of this commori law employer-employee relationship:
  17. 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 …
  18. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  19. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    erest) on the dates shown was as follows: Bate Balance 8/31/78 $123,727.08 8/31/79 131,211.18 8/31/80 141,708.07 8/31/81 144,502.33 4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
  20. 89 T.C. 225; 89 T.C. No. 19 — Professional & Executive Leasing v. Commissioner
    IRCCourt RulingsAug 3, 1987
    …enuous and general than the control over nonprofessional employees” (James v. Commissioner, 25 T.C. 1296, 1301 (1956)), we remain unpersuaded that even a “tenuous and general” control exists in the case before us. See also Azad v. United States, 388 F.2d 74, 77 (8th Cir. 1968). Rather, it is apparent that the recipient…