IRCCourt RulingsApr 16, 2020
…eported Disallowed Conceded At issue
Wages $68,686 $68,686 $65,208 $3,478
Meals and entertainment 2,489 2,489 --- 2,489
Travel 2,456 2,456 --- 2,456
Taxes and licenses 15,317 15,317 15,317 ---
Rent/lease 21,135 21,135 21,135 ---
IRCCourt RulingsFeb 28, 2024★ strong match
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
IRCCourt RulingsJan 14, 2013★ strong match
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…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…age employers from offering . . . benefit plans in the first place.”
Varity Corp.
v.
Howe,
516 U.S. 489, 497 (1996). Congress also knew that plan sponsors and fiduciaries must make a range of decisions and accommodate “competing considerations,” often during periods of considerable market uncertainty. H.R. Rep. No. 96-…
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 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…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…) + 71 small insurers + 10 small robo-advisers + 30 small non-bank trustees) × 10% × 5 hours] + [(1,489 large broker-dealers + (13,409 large registered-investment advisers × 8%) + 13 large insurers + 190 large robo-advisers + 1 large non-bank trustee) × 10% × 10 hours] = 3,156 hours. The equivalent cost is estimated as…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
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 RulingsSep 25, 2019★ strong match
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 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCCourt RulingsNov 25, 2013
… from Mary Kay and received nonemployee
compensation pursuant to the FSP and the GFP agreements of $489,707.
Petitioners timely filed their 2006, 2007, 2008, and 2009 (years in issue) Federal
income tax returns. On Schedules C, Profit or Loss From Business, petitioners
reported "Other Expenses" equaling Mrs. Peterson's…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
IRCCourt RulingsJul 15, 1997
…unt is
deductible as compensation to
petitioner.
38,979 other deduction The corporation conceded
19,489 to be not deductible
for the purpose claimed and
contends that such amount is
deductible as compensation to
petitioner; respondent
conceded 19,489. [1-dollar
mathematical error by the
parties]
823 real estate taxes R…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…iscal year
Dividends declared
Amount paid
3/31/79 $310,640 $310,640
3/31/80 524,888 524,888
3/31/81 489,426 489,426
6/30/81
1
169,440 169,440
1982 1,613,012 1,613,012
1983 204,740 204,740
1984 420,070 420,070
1985 388,300 388,300
1986 76,248 76,248
1987 105,900 105,900
1988 0 0
1989 0 0
1990 5,000,002 5,000,002
1991 0 …
IRCProposed Rules (FR)Proposed May 13, 2026
…,361
877,731
First Year Total Costs
$1,883,462
$1,946,030
Subsequent Year Total Costs
$1,427,080
$1,489,648
L. Alternatives
IRCCourt RulingsFeb 22, 2018
…ce Contracts, etc.,
from JPMorgan for the 2013 taxable year. One showed gross distributions of $116,489.39 from the first account. The other showed gross distributions of
$294,665.64 from the second account. Each had a box checked to indicate that the
taxable amount was not determined. Petitioner and Ms. Kirkpatrick fi…
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 RulingsSep 28, 2022★ strong match
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
IRCCourt RulingsJan 16, 2002★ strong match
cts and circumstances, it is
inequitable to hold the individual liable for any unpaid tax
or any deficiency (or any portion of either) attributable to any item for which relief is not available under the
preceding sentence, the Secretary may relieve such
individual of such liability. .
Petitioner's request for relief r…