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62 documents · 0.56sAllIRCERISAPBGCJoint Board
  1. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987
    SIMPSON, Judge: The Commissioner determined identical deficiencies in each of the individual petitioner’s Federal excise taxes as follows: Year Deficiency 1976 $21,508.32 1977 23,028.47 1978 24,548.62 1979 25,426.67 1980 24,131.43 1981 21,500.00 The Commissioner also determined a deficiency in the Federal excise taxes …
  2. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  3. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    …covered by the plan is a disqualified person. Sec. 4975(e)(2)(H); Rutland v. Commissioner , 89 T.C. 1137, 1144 (1987). Petitioner was vice president of FUH and a member of its board of trustees and its executive committee from 1981 to July 1982, when FUH bought the insurance policies from Travelers, and was an officer …
  4. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  5. Rev. Proc. 2019-19 — This revenue procedure modifies and supersedes Rev. Proc. 2018-52, 2018-42 I.R.B. 611, the most recent prior consolidated statement of the correction programs …
    IRCRevenue ProceduresSuperseded May 6, 2019
    …N ACT DRAFTING INFORMATION APPENDIX A: OPERATIONAL FAILURES AND CORRECTION METHODS .01 General rule 1137 .02 Failure to properly provide the minimum top-heavy benefit under § 416 to non-key employees 1138
  6. Treas. Reg. § 1.430(a)-1(c)(3)(i) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …ooperative and Small Employer Charity Pension Flexibility Act of 2014, Public Law 113-97 (128 Stat. 1137), for special rules that apply to determine the amount of shortfall amortization installments with respect to plan years beginning on or after January 1, 2014, in the case of an eligible charity plan for which the r…
  7. 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…
  8. 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…
  9. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998
    …ithstanding that they may have acted innocently or in good faith. Rutland v. Commissioner , 89 T.C. 1137, 1146 (1987). In signing the
  10. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  11. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    … same: that the loans are prohibited transactions. As we noted in Rutland v. Commissioner , 89 T.C. 1137, 1146 (1987): The language and legislative history of ERISA indicate a congressional intention to create, in section
  12. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000
    …generally are administered by the Department of the Treasury. See Rutland v. Commissioner , 89 T.C. 1137, 1143 n.4 (1987). There are many areas where the labor provisions coincide with or overlap the tax provisions. While much of the statutory terminology is similar, there are instances in which the statutes are differ…
  13. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  14. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016
    …the definition of gross income found in section 61); cf Benson v. Commissioner, 560 F.3d 1133, 1136-1137 (9th Cir. 2009) ¹8We note for completeness that the deemed distributions exceed 25% of the amount of gross income reported on the 2003 joint return. - 25 - (holding that the failure to report constructive dividends …
  15. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
  16. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011
    …rpogeš*. See Blueberri Land Co v. Commissioner, 361 F 2d 93, 1002101. (5th Cir. 1966) affg. 42 T.C. 1137 (1964) . Additionally, it is welal settled that "a e , transaction is to be agiven its, tax effect in abcord with what actua-llymoccurred andonot in accord with what might have- e occurred.2" Commissioner v.s NatldA…
  17. 88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction
    IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
    tax-favored under the same country's laws) must be made in cash and must be based on income earned from employment or self-employment activities. See sections 219, 408, and 408A. Third, in appropriate fact patterns, the transaction viewed as a whole may be disregarded under relevant judicial doctrines, including the s…
  18. 101 T.C. 518; 101 T.C. No. 34 — Janpol v. Commissioner
    IRCCourt RulingsDec 7, 1993
    …n the parallel provisions of 29 U.S.C. sec. 1106(a)(1) (1988). See Rutland v. Commissioner, 89 T.C. 1137, 1146 (1987); Leib v. Commissioner, 88 T.C. 1474, 1480 (1987). With respect to 29 U.S.C. sec. 1106(a)(1)(B), the Court of Appeals in Brock v. Citizens Bank, 841 F.2d 344, 346 (10th Cir. 1988), stated: The district c…
  19. 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…
  20. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …e collection potential exceeded their offer . . . .”); see also Tucker v. Commissioner, 676 F.3d at 1137 (“If the agency’s mistake d id not affect the outcome, if it did not prejudice the petitioner, it would be senseless to vacate and remand for reconsideration.” ( quoting PDK Labs. Inc. v. DEA, 362 F.3d 786, 799 (D.C…