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…
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…
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…
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…
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…
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 …
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 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 …
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…
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…
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 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…
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
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 …
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) .
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…
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…
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),
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…
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 …