IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsFeb 6, 2024
…r,
143 T.C. at 382 ( q uoting Spurlock v. Commissioner, T.C. Memo.
2003- 124, 85 T.C.M. (CCH) 1236, 1244).
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…4, 719 – 20 (1982), aff’d , 731 F.2d 1417 (9th
Cir. 1984); Markosian v. Commissioner, 73 T.C. 1235, 1244 – 45 (1980);
Saccato v. Commissioner, T.C. Memo. 2023-96, at *8. Whether a trust
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 RulingsMar 5, 2018related by meaning
stock. But in substance there was an established expectation and intention
that commission payments would be made, and the Roth IRAs were directed to purchase the FSC stock on the basis of that expectation and intention. The formal
basis for the purchase price therefore did not reflect the substance of the relatedpart…
IRCRegulationsSep 9, 2016
…ividends”, and “annuities” shall have the same meaning such terms are given for purposes of section 1244(c) and § 1.1244(c)-1(e)(1).
(b)(6) (6) Children, grandchildren, parents, and grandparents
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCRegulationsDec 30, 2024
…nterest”, and “annuities” shall have the same meanings such terms are given for purposes of section 1244(c). See paragraph (e)(1)(ii), (iii), (iv), (v), and (vi) of § 1.1244(c)-1.
(b)(6) (6) Children, grandchildren, parents, and grandparents.
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsOct 19, 2010related by meaning
tter of local law and a
State court's determination with regards to such assignment is
not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of
Bosch, 387 U.S. 456, 465 (1967), the Court held that where the
Federal estate tax liability turns upon the chara…
IRCCourt RulingsSep 25, 1996
… a taxpayer's
statement of intent. Simon v. Commissioner
, supra
; Thomas v.
Commissioner
, 84 T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th
Cir. 1986); sec. 1.183-2(a), Income Tax Regs. The promoters and
partners knew enough to stress at trial their personal hopes of
great profits. Thus, while Fred urged them to "t…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
IRCCourt RulingsNov 6, 1962
…a term or for an amount certain despite the annuitant’s death; see, e.g., Elliott C. Morse, 17 T.C. 1244, affd. 202 F. 2d 69 (C.A. 2, 1953); Renton K. Brodie, 1. T.C. 275; but the distinction goes only to value or the amount to be included in income and not forfeitability.
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsAug 30, 2006related by meaning
rough prosecution
of a legal suit or action based upon tort or tort type rights, or
- 14 -
through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the
exclusion must derive from some sort of tort claim against the
payor. Rickel v. Commissioner
, 900 F.2d 655, 65…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…k to Citation
74.
Using data from the BLS for Network and Computer Systems Administrators (Code 15-1244), we estimate that the average hourly labor cost will be $85.02, including 100 percent increase for overhead and fringe benefits.
https://www.bls.gov/oes/current/oes_stru.htm.
Back to Citation
75.
Boynton, A., …
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…