IRCCourt RulingsSep 23, 2019★ strong match
…e Price
At trial petitioner husband testified that the cost basis of the Canadian
property was $189,946 instead of the $137,493 used by respondent. Petitioners
offered into evidence five documents written in French, which they argue
substantiate their claim that the cost basis was $189,946.
Documents written in a langu…
IRCCourt RulingsMay 20, 1976
…taxable years ending in 1970 through 1974 was as follows:
TYENov.30-Taxable income (loss)
1970 ($16,946.11)
1971 16,113.93
1972 — 13,027.89
1973 _ 8,707.05
1974 3,915.97
On March 16, 1971, the corporation filed with the District Director of Internal Revenue, Buffalo, N.Y., an application for determination (Form 4462) c…
IRCCourt RulingsJul 14, 2005related by meaning
0 31
useaee
CAL,
Js.r. Juoca
T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCProposed Rules (FR)Proposed May 13, 2026
…49,681
Enrolled Participants and Beneficiaries
743,361
877,731
First Year Total Costs
$1,883,462
$1,946,030
Subsequent Year Total Costs
$1,427,080
$1,489,648
L. Alternatives
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 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 RulingsFeb 11, 2013
…assignment or alienation of welfare-plan benefits.26 Davidowitz v. Delta Dental Plan of Cal., Inc., 946 F.2d 1476, 1478 (9th
Cir. 1991). And whether such benefits are assignable is left up to the "free
negotiations and agreement of the contracting parties.". St. Francis Reg'l Med. Ctr.
v. Blue Cross & Blue Shield, 49 F…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
IRCCourt RulingsJul 6, 1998★ strong match
…of
September 30, 1994, the account had 15.1473 shares of ESOP stock
which were convertible into 302.946 shares of Gillette common
stock.
On or about December 12, 1994, the plan distributed to
petitioner 302 shares of Gillette common stock with a fair market
value of $73.19 per share at the time of distribution for a to…
IRCCourt RulingsMay 27, 2010
…rbara Curcio (Docket No . 1768-07)
Accuracy-Related Penalty
Year Deficiency Sec . 6662(a )
2001 $79,946 $15,989
2002 81,568 16,314
2003 72,098 14,420
2004 63,519 12,70 4
Ronald D . Jelling and Lorie A . Jelling (Docket No . 1769-07 )
Accuracy-Related Penalty
Year Deficiency Sec . 6662(a )
2001 $79,946 $15,989
2002 81,5…
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 10, 2018related by meaning
bution out of an IRA that is then paid into another IRA owned by the same
owner within 60 days. Id. Under section 408(e)(2)(A), if an IRA engages in a prohibited transaction, the account ceases to be an IRA as of the first day of the
taxable year in which the prohibited transaction occurs.
- 4 -
[*4] Respondent's posit…
IRCCourt RulingsJul 29, 2003
…ns to Tax
Year
Deficiency
Sec. 6651(a)(1)
1
Sec. 6651(a)(2)
Sec. 6654(a)
1996 $62,718 $13,661.55 $3,946.67 $3,164.00
89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption PBGCFinal Rules (FR)Dec 20, 2024
…864
864
3,648
3,648
2029
884
884
3,732
3,732
2030
904
904
3,818
3,818
2031
925
925
3,906
3,906
2032
946
946
3,996
3,996
2033
968
968
4,088
4,088
2034
990
990
4,182
4,182
2035 or later
1,013
1,013
4,278
4,278
1
Applicable tables for valuation dates before 2025 are available on PBGC's website (
www.pbgc.gov).
2
Table I…
IRCCourt RulingsMar 25, 2013
…uction petitioner claimed for officer compensation related to
M. Lipsmeyer for the year 2007 of $62,946; (3) a portion of the deduction
IRCCourt RulingsSep 22, 1998related by meaning
te minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax und…
IRCCourt RulingsMay 19, 2011
…ondent explained that in the notice of deficiency issued to
Mr. Warmoth for 2004 he disallowed $490,946 of the design costs
IRCCourt RulingsJan 16, 2020related by meaning
bed in section 72(t) in respect of Mr. Merrell's IRA
distribution is sustained.
As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case.
We have considered similar claims in the past and have observed that there is no
-8au…
IRCCourt RulingsSep 2, 2021
… 58 T.C.M. (CCH) 606, 608 (1989);
Isenberg v. Com m issioner, T.C. Mem o. 1987-269, 53 T.C.M. (CCH) 946, 955
(1987); Vandenhoff v. Com m issioner, T.C. Mem o. 1987-116, 53 T.C.M. (CCH)
271, 277 (1987). This industry often requires its participants to m aintain a passion
for the work because, without such a passion, a t…