IRCCourt RulingsFeb 25, 2016
… issued the payment to Strategies under the terms of that contract. It is therefore clear that the $680,000 payment was gross income to
Strategies for 2004.
Petitioner argues that Strategies did not err in failing to include the
$680,000 from Delphi in gross receipts on its Form 1120S for 2004. Petitioner
asserts that …
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
…/00/03
Other service: 03/04/21
Sick leave:
.025 service: 23.333333
.03 service:
Average salary: $45,680.80
Total: $26,647.12
Total/month: $2,221.00
Federal Benefit Payment Computation
Birth date: 9/10/46
Hire date: 10/09/77
Freeze date: 06/30/97
Department service: 19/08/22
Other service: 03/04/21
Sick leave:
.025 serv…
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
…/00/03
Other service: 03/04/21
Sick leave:
.025 service: 23.333333
.03 service:
Average salary: $45,680.80
Total: $26,647.12
Total/month: $2,221.00
Federal Benefit Payment Computation
Birth date: 9/10/46
Hire date: 10/09/77
Freeze date: 06/30/97
Department service: 19/08/22
Other service: 03/04/21
Sick leave:
.025 serv…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…is no “contribution or
gift” within the meaning of the statute. Hernandez v. Commissioner, 490 U.S. 680, 701 – 02 (1989). To the extent that a taxpayer receives a
quid pro quo, a charitable contribution deduction is permitted only to
the extent that the value of the transferred property exceeds the value
of the benefit…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
IRCCourt RulingsAug 3, 1979related by meaning
to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption.
II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
IRCProposed Rules (FR)Proposed Dec 23, 2025
les ($67,662,000) from the total annual cost for the original 1PB files ($193,680,000): $193,680,000−$67,662,000 = $126,018,000.
Back to Citation
217. Total network costs for transferring new files (300,000 GB) on a quarterly basis are calculated by multiplying the monthly cost per file transfer ($18,795) by the total…
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…
IRCCourt RulingsOct 3, 1995
ent System and the
- 4 -
4
The parties stipulated that the Transfer Refund amounted
to $158,680.9 6
. The documentary record clearly reveals, however, that the correct amount is $158,680.9 8
.
5
So stipulated. The sum of these two amounts equals
$158,446.20, which is the amount of the check dated March 31,
1990, from t…
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 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…
IRCCourt RulingsMar 12, 2008
…156,68 8
20 156,688 25,000 131,688 11,535 143,22 3
21 143,223 25,000 118,223 10,458 128,68 0
22 128,680 25,000 103,680 9,294 112,97 5
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 RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
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…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
… written description. This results in an hour burden of 2,000 hours with an equivalent cost of $318,680 in the first year.[57]
( printed page 76020)
Table 7—Hour Burden and Equivalent Cost Associated With the Written Description of Service Provided
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Bu…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
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 RulingsFeb 9, 2023★ strong match
…) . Article 45-1,
Regulations 101, was published verbatim in the Federal Register, 4 Fed.
Reg. 616, 680, meaning that the text of article 45- 1 published in the
Federal Register was identical to the text of article 45-1 published in the
pamphlet Regulations 101 Relating to the Income Tax Under the
Revenue Act of 1938 .…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …