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55 documents · 0.50sAllIRCERISAPBGCJoint Board
  1. PLR 201129029 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJul 22, 2011
    …he short sale is considered a gain or loss from the sale or exchange of a capital asse t. Section 1.1233-1(c)(1). Section 1233(b) provides that: If gain or loss from a short sale is considered as gain or loss from the sale or exchange of a capital asset under subsection (a) and if on the date of such short sale substan…
  2. PLR 201105004 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsFeb 4, 2011
    …milar feature if the terms of the contract were significantly altered. Requested Rulin g #5 Section 1233 provides rules as to the tax consequences of a short sale of property if gain or loss from the short sale is considered a gain or loss from the sale or exchange of a capital asset. Section 1.1233-1(c)(1). Section 12…
  3. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    stock. But in substance there was an established expectation and intention that commission payments would be made, and the Roth IRAs were directed to purchase the FSC stock on the basis of that expectation and intention. The formal basis for the purchase price therefore did not reflect the substance of the relatedpart…
  4. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
  5. 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…
  6. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  7. 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…
  8. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  9. 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…
  10. PLR 201603025 — Nonqualified Deferred Compensation
    IRCPrivate Letter RulingsJan 15, 2016
    …ermore, the Stavisky holding applied to a transaction that occurred before the enactment of section 1233. Section 1233(e)(2)(A) treats stock traded on a when-issued basis the same as the stock. Under Example 6 of §1.1233 – 1(c)(6), the price contracted to sell stock when issued applies for purposes of determining the a…
  11. 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 …
  12. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  13. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …analysis of reasonable probability as of 2014. See Estate of Spruill v. Commissioner, 88 T.C. 1197, 1233 (1987) ( “ [S] ubsequent events are generally not relevant in fixing a property ’ s fair market value on a given date . . . . ”). Moreover, LA County’s position cannot bind the Coastal Commission in the
  14. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  15. U.S. Tax Court — Michael Leon & Karin Policky Tilley v. Commissioner
    IRCCourt RulingsJul 21, 2008
    …o mm issioner , 108 T .C . 100, 102-103 (1997) ; F .W . Woolworth Co . v . Commissioner , 54 T .C : 1233, 1265-1266 (1970) .
  16. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  17. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  18. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …How a Uniform Fiduciary Duty Will Better Serve Investors, 2017(3) Colum. Bus. L. Rev. 1200-1243, at 1233-34 (2017),
  19. T.C. Memo. 2012-44 — James Anthony Fonteneaux, Sr. v. Commissioner
    IRCCourt RulingsFeb 21, 2012related by meaning
    Respondent prepared decisiori.documents reflecting respolident's concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and . sanctions against respondent based on "reckless professional behavior." Petitioner is frustr…
  20. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    arding enforceable claims of the parties; and (ii) the parties' assessments of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable outcomes under the governing instruments and applicable State law. Therefore, based …