IRCCourt RulingsOct 21, 2003
1
Unless otherwise indicated, section references are to
(continued...)
T.C. Memo. 2003-294
UNITED STATES TAX COURT
RANDOLPH S. SIMPSON, I, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2832-01. Filed October 21, 2003.
Randolph S. Simpson I, pro se.
Gordon P. Sanz
, for respondent.
MEMORANDUM OP…
IRCCourt RulingsNov 26, 2013
dividends of $2,294.88 over the life of the policy. Petitioner did not
recall including the annual dividends in taxable income when they were paid to him, and there is no evidence that NY Life issued any Forms 1099 that would have
prompted him to do so.
In 2009 petitioner surrendered his policy to NY Life, and the com…
IRCCourt RulingsFeb 9, 2023related by meaning
tions, or any item of either” in the
third paragraph of section 29.45-1(b) was replaced with
“gross income, deductions, credits, or allowances, or any item of gross income, deductions, credits, or allowances”;
● “income or deductions” in the first paragraph of section
29.45-1(c) was replaced with “income, deductions, c…
IRCPrivate Letter RulingsDec 1, 2006
…ht. Accordingly, aggregation was appropriate under those circumstances.
Rev. Rul. 79-7, 1979-1 C.B. 294, holds that stock included in the decedent’s gross
estate under the predecessor to section 2035(a) (requiring inclu sion in the gross estate of
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…
PBGC Op. Ltr. 2001-1 — Becau se the la nguag e of the c ited statu tes is iden tical, thi s letter h ereina fter will PBGCPBGC Opinion LettersFeb 6, 2001
… Int eres t t o 9/15/ 2000
10/15/ 98
[$28,176]
[$32,956]
1/15/ 99
[$62,569]
[$71,692]
4/15/ 99
[$80,294]
[$90,170]
7/15/ 99
[$80,294]
[$88,355]
9/15/ 99
[$76,780]
[$83,325]
10/15/ 99
[$80,294]
[$86,557]
1/15/ 2000
[$80,294]
[$84,795]
4/15/ 2000
[$160,294]
[$165,870]
7/15/ 2000
[$160,294]
[$162,530]
9/15/ 2000
[$319,995…
IRCCourt RulingsJun 6, 2005related by meaning
a matter of
legislative grace, and the burden of clearly showing the right to
the claimed deduction is on the taxpayer. INDOPCO, Inc. v.
Commissioner , 503 U.S. 79, 84 (1992). We are bound by the
Internal Revenue Code, and it is within the province of the
legislature to decide the circumstances of inclusion, deductions…
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…
83 FR 11413 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Mar 15, 2018
Rate Set 294 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set For plans with a valuation date
Immediate
annuity rate
(percent)
Deferred annuities
(percent)
On or after
Before
i1
i2
i3
n1
n2
* * * * …
IRCCourt RulingsMar 13, 2001
…rrespond to the
market value of gold bullion which backed the currency. See
Perry v. United States, 294 U.S. 330 (1935); Nortz v. United
States, 294 U.S. 317 (1935); Norman v. Baltimore & Ohio R.R. Co.,
294 U.S. 240 (1935); Legal Tender Cases, 79 U.S. (12 Wall.) 457
(1870).
As a second ground for rejecting the taxpayer…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…hin the coastal zone are governed by the Coastal Act.
Sierra Club v. Cal. Coastal Comm’n , 111 P.3d 294, 303 (Cal. 2005) (holding that when
a lot straddles the coastal zone boundary, the Coastal Commission retains jurisdiction
over development for the portion of the lot within the coastal zone) . Petitioner provided
no…
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 RulingsMar 5, 1987
…Ill judge does not.
Sec. 371(b) of the Judicial Code. Booth v. United States, supra.
28 U.S.C. sec. 294(b) (1982). Sec. 372(a) of the Judicial Code, unlike sec. 371(b) of the Judicial Code, does not specifically state that the judge retiring under such provision will continue to hold office. However, 28 U.S.C. sec. 294…
IRCCourt RulingsSep 28, 2022
…rain marke ting and storage facility where petitioners stored the crops . CRAT I I distributed $ 69,294
of the proceeds to the charitable remaindermen and used the balance to
purchase a nother SPIA from Symetra . Th is SPIA made annual annuity
payments o f $124, 921 to petitioners in 2016 and 2017. Symetra again
issued…
IRCCourt RulingsMay 28, 1962related by meaning
ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
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 …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ntments that would otherwise arise when medication for chronic diseases is not taken as prescribed.[294]
Using data on medical events from the 2022 MEPS, the Department estimates healthcare utilization for privately insured participants aged 18 to 64 with diabetes, hypertension, or heart disease based on adherence stat…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMar 31, 2015
Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the
IRM provision that addresses the Commissioner's ability to levy upon retirement
accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330
hearing request and provided documents supporting this claim. Settlement Officer
Degiovanni …