IRCCourt RulingsDec 11, 2003★ strong match
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
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsJul 31, 2000
…the second year was $11,830.58, and, at the end of that year, the
conversion credit balance was $81,793.61 ($39,661.58 + $50,440.40
- $11,830.58 + $3,522.21); the $3,522.21 is the interest of 4.5
percent earned on the conversion credit balance (($81,793.61 -
$3,522.21) x 4.5% = $3,522.21)). Of the conversion credit
bal…
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
…care benefits. The Trustee further
acknowledges that it reported in Form 990-T for 1992 only
$1,155,793 of its investment income for that year as unrelated
business income. Respondent made no determination in the notice
that the Trust’s remaining investment income for 1992 (i.e.,
$405,095), which the Trust did not trea…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…the disclosures would require four pages in total, resulting in a material and postage cost of $158,793.[48]
Table 9—Material and Postage Cost Associated With Sending Disclosures
Year 1
Subsequent years
Activity
Pages
Cost
Pages
Cost
Material Cost
4
$158,793
4
$158,793
Total
4
158,793
4
158,793
1.4 Costs Associated W…
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…
IRCProposed Rules (FR)Proposed Nov 27, 2019
…of
responses
Burden hours
per respondent
Total burden
hours
Total cost
1,959
23,508
156
305,604
$28,793,069 The Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,527,110 hours and an equivalent associated cost of approximately $230,686,747 to develop and build the Allowe…
IRCCourt RulingsJan 3, 2011
… 2004, petitioner' s policy yas
credited~ eith an" $18 000 premium payment and Nas credÏted with
$2,793 in interest, yielding a total ofs$20,793. ,However,
petitioner'â ]'ife insurance policy incurred a mortality charge of
$8, 496 and other expenses of $2, 640, for, a net value for his 2004
tax yRr of $9 è$7 Indludidg …
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 RulingsAug 1, 1996
… reduced drastically. In
order to pay off his debts, petitioner made early withdrawals
totaling $24,793.94 from his two retirement plans during 1992.
- 3 -
Specifically, petitioner received a distribution of $14,793.94
from the SEP plan and a distribution of $10,000 from the Keogh
plan. Petitioner received a Form 1099-…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
IRCCourt RulingsNov 21, 2007
… to Tax/Penaltie s
Year Deficiency Sec . 6651(a)(1) Sec . 6662(a )
1999 $94,699 .32
$23,674 .83 $12,793 .1 3
2000 1,000 .00 None Non e
Unless stated otherwise, all section references in this opinion
are to the Internal Revenue Code as in effect during the years in
issue .
The issues for decision are
: (1) Whether the d…
T.C. Memo. 2017-142 — Block Developers, LLC, William J. Maxam, APC, Tax Matters Partner v. Commissioner IRCCourt RulingsJul 18, 2017
…tom lines:¹4
Additions to tax
Petitioner Excise Tax Sec. 6651(a)(1) Sec. 6651(a)(2)
Mr. Jansson $11,793 $2,653.42 $1,827.91
Mrs. Jansson 11,793 2,653.42 1,827.91
Niklas 11,793 2,653.43 1,827.92
Fred 11,793 2,653.43 1,827.92
We consolidated the cases and tried them in San Diego. Block's principal
place of business was i…
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…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026
…R.B. 2026-05 416
Treasury Decisions:—Continued
Article Issue Link Page
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 840
10045 2026-21 I.R.B. 2026-21 1491
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
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…
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…