IRCCourt RulingsDec 30, 1998
…56,000
Based on the evidence before us, we conclude that
petitioner's tax basis in her home is $277,633, or $56,000 over
the $221,633 allowed by respondent.
- 14 -
Miscellaneous Itemized Deductions
With respect to the claimed $1,000 consulting fee in excess
IRCCourt RulingsSep 25, 1996
…ould have
appeared in the Termination Agreement was $2,135,260), and that
MPC offered to pay $1,899,633. MPC proposed to do so by
transferring to MIT 83 the note made by Qulart on July 1, 1983,
in favor of Machise in the amount of $2,888,666. The balance on
the note as of January 1, 1988, was $1,899,633. MIT 83 accepte…
IRCCourt RulingsMay 3, 1995
Cumulative Difference
-0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji
1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3
Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…
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 RulingsMar 31, 2015related by meaning
… upon retirement
accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330
hearing request and provided documents supporting this claim. Settlement Officer
Degiovanni was aware that Mrs. Gurule and petitioners' middle son suffered from
severe medical conditions that left them with high med…
IRCCourt RulingsOct 11, 1995
…o. 1995-27;
Hoppe v. Commissioner
, T.C. Memo. 1994-635; Hamilton v.
Commissioner
, T.C. Memo. 1994-633; Maryland State Teachers
Association v. Hughes
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 RulingsFeb 9, 2023★ strong match
…source of information in a deficiency
case such as this one. See Wilkinson v. Commissioner, 71 T.C. 633, 639 ( 1979).
48
During 2006, 3M Brazil paid $52,522,080 in dividends and
$11,978,720 in interest on net equ ity to 3M IPC. The total of these
payments is $64,500,800.
In 2006, 3M Brazil made no payments to 3M Compan…
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 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 RulingsJul 11, 2012
…16,392 16,392
Amount Amount
Expenses claimed determined
Food, clothing, and miscellaneous $1,250 $1,633
Housing and utilities . 6,279 2,519
Vehicle operating costs 650 650
Public transportation 362 182
Health insurance 480 480
Out-of-pocket health costs 150 300
Court-ordered payments 633 633
Life insurance 400 400
Taxe…
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 RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
acted section
7476 to establish a declaratory judgment procedure under which an
- 6 -
employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept.
93-807, supra
at 107, 1974-3 C.B. at 342. Section 7476 provides:
SEC. 7476. DECLARATORY JUDGMENTS
RELATING TO…
IRCCourt RulingsOct 3, 1995
…o. 1995-27;
Hoppe v. Commissioner
, T.C. Memo. 1994-635; Hamilton v.
Commissioner
, T.C. Memo. 1994-633; Maryland State Teachers
Association v. Hughes
, 594 F. Supp. 1353, 1357-1358 (D. Md.
1984).
4
So stipulated.
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…the Affected Entities section of the RIA.
Back to Citation
624. The burden is estimated as: (3,088,633 rollovers × 48% × (30 minutes ÷ 60 minutes)) + (3,088,633 rollovers × 52% × (5 minutes ÷ 60 minutes)) = 875,113 hours. A labor rate of $219.23 is used for a personal financial adviser. The labor rate is applied in th…
IRCCourt RulingsNov 17, 2016
…imum Petitioner Respondent
2002 $160,000 $69,740 $52,935
2003 160,000 69,687 53,150
2004 165,000 71,633 54,811
2005 170,000 74,170 56,472
2006 175,000 76,352 58,133
In view of his computation pursuant to section 415(b)(2)(C) of lower reduced
benefit limits, respondent in the notice of deficiency further calculated allo…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…failures
632
.03 Effect of VCP submission on examination
632
.04 No concurrent examination activity
633
.05 Determination letter applications not related to a VCP submission
633
.06 Processing of submission
633
.07 Compliance statement
634
.08 Effect of compliance statement on examination
635
.09 Special rules relating…
IRCCourt RulingsMay 23, 2011
…(c) (4) superfluous. See sec. 402(i); Weinberger v.
Hynson, Westcott & Dunning, Inc., 412 U.S. 609, 633 (1973) (an
interpretation that renders a statutory provision superfluous
77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 30, 2012
… at URA is greater than—
From—
To—
2014
599
599
2,531
2,531
2015
611
611
2,582
2,582
2016
623
623
2,633
2,633
2017
636
636
2,688
2,688
2018
649
649
2,745
2,745
2019
663
663
2,803
2,803
2020
677
677
2,861
2,861
2021
691
691
2,922
2,922
2022
706
706
2,983
2,983
2023 or later
720
720
3,046
3,046
1
Table II-A.
2
Table II…