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54 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …ffiliated corporations to file consolidated returns”. B. Forman Co. v. Commissioner, 453 F.2d 1144, 1150 (2d Cir. 1972), aff’g in part , rev’g in part 54 T.C. 912 (1970). These statements are incorrect. The history of the Revenue Act of 1928 began with a bill that was introduced in the House and then referred to the Ho…
  2. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    ents was this estimate, to which respondent reserved an objection on grounds of relevance and authenticity. We overrule respondent's objection. - 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets to the extent of the gain from such sales or exchanges, plus the lower of: (1) $3,000 o…
  3. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976
    …d at 393-394; Cornell-Young Co. v. United States, 469 F.2d at 1324; George Loevsky, 55 T.C. at 1149-1150.
  4. 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…
  5. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979
    …ories, Inc. v. Commissioner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960).
  6. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  7. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
  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. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976
    …, 631-632 (1974), affd. per curiam 518 F.2d 554 (8th Cir. 1975); George Loevsky, 55 T.C. 1144, 1149-1150 (1971), affd. per curiam 471 F.2d 1178 (3d Cir. 1973), cert. denied 412 U.S. 919 (1973); Ed & Jim Fleitz, Inc., 50 T.C. 384, 390 (1968); John Duguid & Sons, Inc. v. United States, 278 F.Supp. 101, 105 (N.D. N.Y. 196…
  10. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007related by meaning
    iable for the $1,990 10-percent additional tax on the $19,900 early IRA distribution Mary received. To reflect the foregoing, Decision will be entered under Rule 155 .
  11. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  12. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  13. 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…
  14. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  15. 80 FR 72006 — Savings Arrangements Established by States for Non-Governmental Employees
    ERISAProposed Rules (FR)Proposed Nov 18, 2015
    …s.” Back to Citation 4.  Illinois Secure Choice Savings Program Act, 2014 Ill. Legis. Serv. P.A. 98-1150 (S.B. 2758) (West); California Secure Choice Retirement Savings Act, 2012 Cal. Legis. Serv. Ch. 734 (S.B. 1234) (West); Oregon 2015 Session Laws, Ch. 557 (H.B. 2960) (June 2015). Back to Citation 5.
  16. 80 FR 71936 — Interpretive Bulletin Relating to State Savings Programs That Sponsor or Facilitate Plans Covered by the Employee Retirement Income Security Act of 1974
    ERISAFinal Rules (FR)Nov 18, 2015
    …(H.B. 2960) (June 2015); Illinois Secure Choice Savings Program Act, 2014 Ill. Legis. Serv. P.A. 98-1150 (S.B. 2758) (West); California Secure Choice Retirement Savings Act, 2012 Cal. Legis. Serv. Ch. 734 (S.B. 1234) (West). These IRA-based initiatives generally require specified employers to deduct amounts from their …
  17. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979
    …e 182(c) and (d), and the Note thereto, Tax Court Rules of Practice and Procedure, 60 T.C.1057,1149-1150 (1973). FINDINGS OF FACT Some of the facts have been stipulated and those facts are so found. The stipulation of facts, supplemental stipulation of facts, and all attached exhibits are incorporated herein by this re…
  18. 81 T.C. 652; 81 T.C. No. 38 — Doty v. Commissioner
    IRCCourt RulingsSep 28, 1983
    …ble to her. Johnson v. United States, 135 F.2d 125 (9th Cir. 1943); Hubner v. Commissioner, 28 T.C. 1150 (1957). Indeed, there is no dispute between the parties with respect to this point. The question, simply stated, is whether the income received by petitioner constituted earned income under section 1348.
  19. Ann. 2007-47 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsMay 14, 2007
    …oor New York, NY 10038 2/11/1992 210. SBM Financial Services, Inc. 8400 Normandale Lake Blvd. Suite 1150 Minneapolis, MN 55437 5/13/1995 211. Scott & Stringfellow, Inc. (FKA Craige, Inc.) 823 E. Main Street Richmond, VA 23219 5/5/1999 212. Scottsdale Securities, Inc. 12855 Flushing Meadow St. Louis, MO 63131 10/9/1996 …
  20. Ann. 2006-45 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsJul 31, 2006
    …New York, NY 10038 2/11/1992 206. SBM Financial Services, Inc. 8400 Normandale Lake Boulevard Suite 1150 Minneapolis, MN 55437 5/13/1995 207. Scott & Stringfellow, Inc. (FKA Craige, Inc.) 823 E. Main Street Richmond, VA 23219 5/5/1999 208. Scottsdale Securities, Inc. 12855 Flushing Meadow St. Louis, MO 63131 10/9/1996 …