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1. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
   IRCCourt RulingsJan 30, 2007
   …05-176. The Plan 15104 Form W-2 reflects a gross distribution to petitioner from Plan 15104 of $372,850 and that petitioner made no employee contributions to Plan 15104. The parties stipulated the accuracy of the Plan 15104 Form W-2, and no evidence in the record contradicts the Plan 15104 Fórm W-2. This evidence, if n…
2. Treas. Reg. § 1.412(c)(1)-2(g)(6) — Shortfall method.
   IRCRegulationsSep 9, 2016
   ning of the year) is $900,850, and that actual contributions at the rate of $1.75 per unit are paid at mid-year in 1976. (A) Computation of the Unfunded Liability as of December 31, 1976 1. Unfunded liability as of 1/1/76 $900,850 2. Normal cost (that used in the calculation of the total annual computation charges) 100…
3. 72 T.C. 377 — La Mastro v. Commissioner
   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…
4. 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…
5. Treas. Reg. § 1.402A-1(b) — Designated Roth Accounts.
   IRCRegulationsSep 17, 2024
   …om C's designated Roth account. Immediately prior to the distribution, the account consisted of $21,850 of investment in the contract (i.e., designated Roth contributions) and $1,150 of income. For purposes of determining recovery of investment in the contract under section 72, the distribution is deemed to consist of …
6. REG-146459-05 — Proposed regulations under sections 402A, 408A, and 402(g) of the Code set forth the tax treatment of designated Roth contributions (and related earnings) that…
   IRCProposed Rules (FR)Proposed Feb 21, 2006
   …om C’s designated Roth account. Immediately prior to the distribution, the account consisted of $21,850 of investment in the contract (i.e., designated Roth contributions) and $1,150 of income. For purposes of determining recovery of investment in the contract under section 72, the distribution is deemed to consist of …
7. 66 T.C. 324 — Bianchi v. Commissioner
   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…
8. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
   IRCCourt RulingsMar 7, 2019
   … -- -- B 1510 Equipment-- Alpha 9/8/2003 6,500 6,500 -- -- -- -- -- E Equipment--Krom. 10/20/2003 5,850 5,850 -- -- -- E 1520 Equipment-- Alpha 10/31/2003 9,800 9,800 -- -- -- E 1620 w/RC Equipment--Krom. 12/19/2003 10,250 10,250 -- -- -- E - 29 - [*29] Telephone System 12/31/2003 4,514 4,514 -- -- -- F TC33D Equipment…
9. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
   IRCCourt RulingsApr 16, 2020
   …el 3,465 3,465 --- 3,465 Supplies 390 390 --- 390 Rent/lease 533 533 --- 533 Legal and professional 850 850 --- 850 Interest 4,532 4,532 --- 4,532 Depreciation 33,875 33,875 --- 33,875 Car and truck 5,506 5,506 --- 5,506 i. Other Expenses We have found that in 2013 petitioner husband, on behalf of GSE, paid $4,465 for …
10. 73 T.C. 700 — Grant-Jacoby, Inc. v. Commissioner
    IRCCourt RulingsJan 16, 1980
    …k Number of shares owned Percent of issued stock Robert L. Flink 1,380 29 1,380 27 Bruce I. Carlson 850 18 850 17 Robert Krewer 850 18 850 17 Charles A. Norris 850 18 850 17 Robert Lavender 750 16 750 15 William Harkins 0 0 300 6 Hiroki Mizushima _0 0 100 2 Total shares 4,680 5,080 As a means of remaining competitive i…
11. 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…
12. T.C. Summary Opinion 2018-16 — Albert Anthony Oliver v. Commissioner
    IRCCourt RulingsApr 3, 2018
    determined that petitioner should have reported $44,850 of taxable retirement distributions, reflecting an additional $7,200 from CalPERS. Discussion The Commissioner's determinations in a notice of deficiency are generally presumed correct, and the taxpayer bears the burden of proving those 2CalPERS calculated the no…
13. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968★ strong match
    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…
14. Treas. Reg. § 1.101-4(ii)(2) — Payment of life insurance proceeds at a date later than death.
    IRCRegulationsJan 19, 2017
    …t rate. The prorated amount is $15,000 ($150,000 ÷ 10). As the second payment, the insurer pays $17,850, which exceeds the guaranteed payment by $1,350 as the result of earnings of the insurer in excess of those required to pay the guaranteed installments. The surviving spouse shall include $1,850 in gross income and e…
15. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
16. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …ed burden for Federal external review to individual market and non-Federal Government plans is $241,850. This amount includes $222,729 in costs for non-grandfathered plans and $19,121 for grandfathered plans. The existing collection for HHS for Federal external review is $128,876. Table 61—HHS' Summary Table New Collec…
17. 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 .
18. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan. Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
19. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
20. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…