IRCCourt RulingsSep 19, 1978
…hange in the character of petitioner’s business and the composition of its work force (see pp. 1013-1014 infra) — changes as to which respondent cam hardly have been said to have been on notice-to say nothing of the fact that the claimed unforeseen circumstances developed prior to the taxable years at issue herein (see…
IRCRegulationsJan 19, 2017
…state or the person receiving the stock by bequest or inheritance shall be determined under section 1014 or under section 1022, if applicable, and shall not be increased by reason of the inclusion upon the decedent's death of any amount in the decedent's gross income under this paragraph (k). See Example (9) of this pa…
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…
IRCRegulationsJan 19, 2017
…would be increased by 1/10th of $100, or $10. The option acquires a basis, determined under section 1014(a) or under section 1022, if applicable, only if the transfer of the share pursuant to the exercise of such option qualifies for the special tax treatment provided by section 421(a). To the extent the option is so e…
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 RulingsApr 22, 2003related by meaning
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
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…
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 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov… IRCTreasury DecisionsAug 15, 2016related by meaning
ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred.
EMPLOYEE PLANS
T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…es have the power to distribute income or principal to themselves by unanimous consent.
(8) Section 1014.—Basis of Property Acquired from a Decedent.—Whether the assets in a grantor trust receive a § 1014 basis adjustment at the death of the deemed owner of the trust for income tax purposes when those assets are not in…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsApr 19, 2006
… Woods v. Commissioner
, 92 T.C. 776, 784-787 (1989);
Estate of Rosenberg v. Commissioner
, 73 T.C. 1014, 1017-1018
REG-106251-08 — Proposed regulations under section 423 of the Code provide the requirements that must be satisfied in order for a plan to meet the definition of an employee st… IRCProposed Rules (FR)Proposed Sep 29, 2008
…state or the person receiving the stock by bequest or inheritance shall be determined under section 1014, and shall not be increased by reason of the inclusion upon the decedent’s death of any amount in the decedent’s gross income under this paragraph (k). See Example (9) of this paragraph with respect to the determina…
IRCCourt RulingsNov 10, 2020
…mmissioner, T.C. Memo. 2016-28, at *8 (citing section 1.408-2(e), Income Tax
Regs.), affd, 860 F.3d 1014 (7th Cir. 2017).
Section 408(d)(1) provides that any amount paid or distributed out of an
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…
IRCRegulationsJan 19, 2017
… of the survivor where joint ownership is terminated by the death of one of the owners, see section 1014 or section 1022, if applicable.
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 RulingsApr 17, 2012
…); Woods v. Commissioner, 92 T.C. 776, 784-787 (1989);
Estate of Rosenberg v. Cbmmissioner, 73 T.C. 1014, 1017-1018 (1980); Hays
Corp. v. Commissioner, 40 T.C. 436, 442-443 (1963), aff'd, 331 F.2d 422 (7th Cir.
IRCCourt RulingsSep 14, 1993related by meaning
r in the computation of the sec. 72(t) tax, her petition raised the issue whether she should have been subject to any additional tax under sec. 72(t). Sec. 402(e)(1) has been redesignated sec. 402(d) by the Unemployment Compensation Amendments of 1992, Pub. L. 102-318, sec. 521(a) and (b), 106 Stat. 290, 300-310, 313, …