IRCCourt RulingsDec 18, 2012
…-0-
(205,102)
Nontaxable
items
-0-
-0-
(113,589)
-0-
-0-
-0-
(113,589)
Both
petitioners'
income
(10,963)
-0-
-0-
-0-
-0-
-0-
(10,963)
Ms.
Zaklama's
income
-0-
(700)
-0-
-0-
-0-
-0-
(700)
Mr.
Zaklama's
income
(41,150)
-0-
(21,266)
-0-
-0-
(21,422)
(83,838)
Rental
income
(10,368)
(10,466)
(8,916)
-0-
-0-
(12.061)
(41.811…
IRCCourt RulingsJan 30, 2007
…dent's assertions and argue that,
of the $746,191 reported as taxable income on hhe Intel W-2,
$606,963 is not included in gross income.9
Petitioners also received but did not report a State
income tax refund of $34,500. As noted above, the parties agree
that petitioners are liable for Federal income tax in 2000 on
tha…
IRCCourt RulingsNov 15, 2004
Const. Co., Inc.,
963 F.2d 1005 (7th Cir. 1992), is "a critical case in this area".
The cited Court of Appeals opinion deals with a number of issues. We assume petitioner intends us to focus on that part of the
Etter opinion dealing with whether an employees plan's investment
in a joint venture "constituted a use of t…
IRCCourt RulingsFeb 28, 2024related by meaning
004 made
an excess contribution of $25,132,892 to his individual retirement account (IRA). Section 4973(a)
1
imposes an excise tax “in an amount equal to 6 percent of the amount of the excess contributions” that a taxpayer
makes to an IRA in any given year. This tax continues to apply for future years, until such time …
IRCCourt RulingsJan 2, 2020★ strong match
…Insurance 1,310
Legal and professional
fees 1,500
Legal and professional
fees 2,750
Other 510
Other 963
Depreciation or
depletion 836
Depreciation or
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 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 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 RulingsJan 29, 2019
… is entitled to Schedule A miscellaneous itemized
deductions of $89 for tax preparation fees and $1,963 for attorney's and
accountant's fees for 2009 and $106 for tax preparation fees for 2010;
(6) whether petitioner is entitled to a Schedule A deduction for charitable
contributions of $18,414, an amount greater than r…
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 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 RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
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 RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…st of $124 million.
Table 12—Hour Burden
Year 1
Year 2
Year 3
Average
Service Providers
2,197,000
963,000
963,000
1,374,000
Plans
733,000
114,000
114,000
320,000
Total
2,930,000
1,076,000
1,076,000
1,694,000
Note:
The displayed numbers are rounded to the nearest thousand and therefore may not add up to the totals.
Ta…
85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 7, 2020
…High 4
if monthly
benefit at URA
is greater than—
From—
To—
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
2029
804
804
3,396
3,396
2030
822
822
3,474
3,474
2031 or later
841
841
3,554
3,554
1…
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-…
83 FR 63802 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 12, 2018
…From—
To—
2020
655
655
2,767
2,767
2021
670
670
2,831
2,831
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
2029 or later
804
804
3,396
3,396
1
Applicable tables for valuation dates before 201…
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…