IRCCourt RulingsDec 18, 2012
T.C. Memo. 2012-346
UNITED STATES TAX COURT
SELVIA ZAKLAMA, ET AL.,' Petitioners v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket Nos. 9275-03, 9276-03, Filed December 18, 2012.
9277-03.
Esmát Zaklama, pro se.
Selvia Zaklama, pro se.
Steven W. Ianacone and Joseph J. Boylan, for respondent.
1Cases of the following…
ERISACourt RulingsJan 20, 1998
…, 1986,
and on October 13, 1986, Respondents rolled the net proceeds of CD
No. 328 over into CD No. 346, issued by Brighton Bank in the name
of "Smith Administrators Medical Claims Account."6 Ex. C6. On the same day,
Respondents renewed Loan No. 25-20129-4 and pledged CD No. 346 as
collateral for the loan. Respondents …
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…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
IRCCourt RulingsMay 8, 2017
…al annual
annuity payment of $28,937 multiplied by the multiple shown in Table V of 58.0,
or $1,678,346 ($28,937 × 58.0 = $1,678,346).
The exclusion ratio is computed by dividing the investment in the contract
of $5,000 by the expected return of $1,678,346, or 0.002979 ($5,000 ÷ $1,678,346
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…to the contract, or if the plan frequently changes benefits, then it is best to audit every year.” [346]
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 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 RulingsApr 16, 2020
…ted the amounts listed below:
I_tern Reported Disallowed Conceded At issue
Meals and entertainment $346 $346 --- $346
Travel 401 401 --- 401
Office expenses 677 677 --- 677
Advertising 289 289 --- 289
i. Meals and Entertainment
For the reasons explained supra part II(A)(2)(i), petitioners failed to satisfy
the substant…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
mates that plans will produce
( printed page 36944)
730,346 notices in 2022.[206]
This results in a cost burden of approximately $18,259 in 2022.[207] DOL shares this burden equally with the Department of the Treasury. Therefore, the total cost burden for DOL is approximately $9,129 and the total cost burden for the Tr…
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…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsJun 18, 1997related by meaning
r personal injuries or
sickness to the extent such amounts are (A) attributable to
- 11 -
7
Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining
age 65 by completely disabled persons retired on disability.
Sec. 105(d) was repealed by sec. 122(b) of t…
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 RulingsAug 18, 2015
…veral years previously. Between 2003
and 2006 petitioners made additional after-tax investments of $346,154 in the
Allstate annuity contract.
In March 2007 petitioners surrendered the Allstate annuity and transferred
the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of th…