IRCCourt RulingsMar 5, 2018related by meaning
on of the substance over form doctrine. We disagree. We are not bound
to follow Summa Holdings II in these cases, which are appealable to the Court of Appeals for the Ninth Circuit in the absence of a stipulation to the contrary. M
sec. 7482(b)(1)(A), (2). In any event, the holding in Summa Holdings II pertained
to a r…
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…nonprofit employer and its religious employees.
Real Alternatives,
150 F. Supp. 3d 419,
affirmed by
867 F.3d 338 (3d Cir. 2017). One member of the appeals court panel in
Real Alternatives
v.
Sec'y of HHS
dissented in part, stating he would have ruled in favor of the individual employee plaintiffs under RFRA. 867 F.3d 3…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
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 2, 2020★ strong match
…om Schedule E to Schedule A, Itemized Deductions.
Petitioners claimed an NOL carryforward of $1,439,867 for 2007 but did
not attach any statement describing or computing that amount. The claimed NOL
is based on a Form 1040X, Amended U.S. Individual Income Tax Return,
petitioners filed on April 23, 2007, for the tax yea…
IRCCourt RulingsJul 31, 1989
… The Merrill Lynch account statement records these transactions as follows:
Ready-Asset Account No. 867 79549
DATE TRANSACTION DESCRIPTION PRICE AMOUNT
* * *
08 12 FUNDS RECEIVED FUNDS RECEIVED $37662.54CR
08 17 RECEIVED 1994 SEARS ROEBUCK
The records of Merrill Lynch show that petitioner’s IRA rollover account was set…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsMar 18, 2015
…mount of
$32,000 equals an excess above base amount of $7,735; one-half of excess base
amount is $3,867.50; one-half of Social Security benefits is $9,566; the amount
includible in gross income is $3,867.50 (rounded up to the nearest dollar, $3,868).
_ 9 _
87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCProposed Rules (FR)Proposed May 5, 2022
…e expected term of 22 years into the present value of the hypothetical fund ($1,075,084.50/22 = $48,867.48).
(D) In the fourth step, the corpus portion of each annuity payment is determined by dividing the corpus amount of each annual payment by the annual annuity payment (adjusted for payments more frequently than ann…
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…
88 FR 37424 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCFinal Rules (FR)Jun 7, 2023
…e expected term of 22 years into the present value of the hypothetical fund ($1,075,084.50/22 = $48,867.48).
(D) In the fourth step, the corpus portion of each annuity payment is determined by dividing the corpus amount of each annual payment by the annual annuity payment (adjusted for payments more frequently than ann…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
Notice 2025-60 — This notice sets forth the 2025 Required Amendments List (2025 RA List). The 2025 RA List applies to individually designed plans qualified under section 401(a)… IRCNoticesDec 22, 2025
…r comments regarding section 530A and related sections of the Code.
INCOME TAX
Notice 2025-75, page 867.
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. …
IRCCourt RulingsJul 22, 1980
…Times Corp. v. United States, 361 F. Supp. 222 (D. N.J. 1973); Dejay Stores, Inc. v. Ryan, 229 F.2d 867 (2d Cir. 1956). Moreover, petitioner emphasizes that absent a written trust and plan, the District Court in Hill York Corp. v. United States, an unreported case (S.D. Fla. 1964, 14 AFTR 2d 5160, 64-2 USTC par. 9654),…
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
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…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
e Technical and Miscellaneous Revenue Act of 1988 (102 Stat. 3700) (TAMRA), are satisfied (see §1.457-2(b)(4) for a special rule regarding such plan); (ii) A collectively bargained nonelective deferred compensation plan in effect on December 31, 1987, if the conditions of section 6064(d)(2) of TAMRA are satisfied;
(iii…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…