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 …
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJan 14, 2013★ strong match
…1 26,899 -0- 26,899 6,151 -0- 6,151
1980 25,952 -0- 25,952 5,900 -0- 5,900
1979 25,037 -0- 25,037 5,660 -0- 5,660
1978 24,155 -0- 24,155 5,429 -0- 5,429
1977 23,304 -0- 23,304 5,208 -0- 5,208
1976 22,484 -0- 22,484 4,996 -0- 4,996
1975 21,691 -0- 21,691 4,792 -0- 4,792
1974 20,927 -0- 20,927 4,597 -0- 4,597
1973 20,190…
IRCCourt RulingsJul 8, 2020
…he amount petitioner
actually paid during calendar 2016.
On her return petitioner reported that $24,660 of her distributions was
subject to the 10% additional tax under section 72(t). By negative implication this
suggests that the expenses she believed to be exempt from the 10% additional tax
totaled $29,840 ($54,500 -…
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…
IRCCourt RulingsMay 23, 1979related by meaning
petitioner sought to deduct, as the sole shareholder, the entire net operating loss of $16,946.11 for the initial short taxable year on his Form 1040. We held in Bianchi that the contribution, including the compensation paid to petitioner during the initial 7-day taxable year, was unreasonable and properly disallowed, …
IRCCourt RulingsDec 18, 2012
…counts at California
Federal Bank F.S.B. (CFB9263).
During 1996 Mr. Zaklama withdrew $42,711 and $8,660 from his IRAs at
Trust Company Bank (TCB5084) and Downey Savings & Loan (DSL5084),
IRCCourt RulingsMar 18, 1992
… to the return, petitioners stated the following:
IRA distributions from—
First Maryland S&L. *$ 10,660
Less amount rolled over . 10,660
Taxable..0
'The parties stipulated that the two checks received were $8,373 and $2,286 (total $10,659). There is nothing in the record to explain why petitioners reflected $10,660 in …
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…es
650
.03 Vesting Failures
657
.04 § 415 Failures
658
.05 Correction of Other Overpayment Failures
660
.06 § 401(a)(17) Failures
660
.07 Correction by Amendment
660
SECTION 3. EARNINGS ADJUSTMENT METHODS AND EXAMPLES
.01 Earnings Adjustment Methods
661
.02 Examples.
663
PART I. INTRODUCTION TO EMPLOYEE PLANS COMPLIANC…
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…
IRCCourt RulingsAug 27, 2026
…e appellate court
affirmed. See Janangelo v. Treasury Inspector Gen. for Tax Admin. , 726
F. App’ x 660 ( 9th Cir. 2018). Mr. Janangelo’s FOI A litigation ended
when the Supreme Court of the United States denied his petition for
writ of certiorari. See Janangelo v. Treasury Inspector Gen. for Tax
Admin . , 586 U.S. 999…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsApr 18, 1996
…a deduction for any of the claimed $6,201
automobile expenses.
b. Interest
Petitioners deducte d $1,660 as an interest expense. They
presented evidence that they incurred this expense with regard to
the Cadillac. Because the parties have stipulated that petitioner
used the Cadillac 82 percent of the time for business u…
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. …
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ubdivision would require 33 transfer development credit s
necessitating retirement of approximately 660 acres of qualifying
coastal land. The record does not establish that such credits were
available or reasonably obtainable. In addition, several proposed
building pads appear to encroach upon ridgeline setback s and h…
76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary IRCProposed Rules (FR)Proposed Aug 22, 2011
…es
SBC Requirements—Issuers
440
540,000
$18,000,000
$2,900,000
41,000,000
SBC Requirements—TPAs
750
660,000
23,000,000
3,700,000
49,000,000 Coverage Example Requirements—Issuers
440
140,000
7,600,000
1,500,000
41,000,000
Coverage Example Requirements—TPAs
750
240,000
13,000,000
1,800,000
49,000,000
Glossary Requests—Is…
IRCCourt RulingsJun 30, 1982related by meaning
ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
IRCFinal Rules (FR)Nov 12, 2020
…3(b)(i); 2590.715-2715A3(b)(i); and 147.212(b)(1)(i)
0938-1372
1,959
16,325
3,199
6,266,188
848,390,660.00
0
848,390,660.00
§§ 54.9815-2715A3(b)(1)(ii); 2590.715-2715A3(b)(1)(ii); and 147.212(b)(1)(ii)
0938-1372
1,959
16,325
1,651
3,233,656
453,887,240.00
0
453,887,240.00
§§ 54.9815-2715A3(b)(1)(iii); 2590.715-2715A3(b…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
ar 1954 under the provisions of section 404(a)(5), and section 1.404(a)-12, Income Tax Regs.
On brief, petitioner states the “Issue To Be Decided” as— Where the petitioner obligated itself to pay to the widow of its deceased President an amount equivalent to the monthly salary of the deceased President for a period of …
ERISACourt RulingsAug 14, 2026
…esembles their
arguments against commonality. See Priddy v. Health Care
Serv. Corp. , 870 F.3d 657, 660 (7th Cir. 2017) (the issue of “commonality and typicality tend to merge”) (quoting Gen. Tel. Co.