IRCCourt RulingsJan 17, 2024★ strong match
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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ated in part, and remanded on another issue sub nom.
JPMorgan Chase & Co. v. Commissioner, 458 F.3d 564 (7th Cir. 2006).
The usefulness of any approach depends on the nature of the property
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…tation
831.
The burden is estimated as: 2,197,679 rollovers × 27.6% involving small entities = 605,564 small rollovers. The labor rate of $64.60 per rollover (based on a rate of $228 per hour for a Personal Financial Adviser) and a material cost of $0.10 per paper rollover disclosure are applied in the following calcu…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…ion of such a test that: (1) Is approved, cleared, or authorized under section 510(k), 513, 515, or 564 of the FD&C Act (21 U.S.C. 360(k), 360c, 360e, 360bbb-3); (2) the developer has requested, or intends to request, emergency use authorization under section 564 of the FD&C Act (21 U.S.C. 360bbb-3), unless and until t…
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 RulingsJun 18, 1999★ strong match
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
ERISACourt RulingsAug 14, 2026
…n each class member would be entitled to an individualized award of monetary damages.” Wal - Mart , 564 U.S. at 360–61. This is not to say,
however, that a member in a Rule 23(b)(2) class cannot receive
any monetary relief at all; rather, to the extent that the class
members receive such relief, it must be “incidental …
IRCCourt RulingsJan 2, 2008
…l Rule references are to the Tax Court
Rules of Practice and Procedure .
Respondent determined a $6,564 deficiency in petitioner's
2003 Federal income tax and an accuracy-related penalty of $662
pursuant to section 6662(a) .
After concessions,' the issues for decision are : (1) Whether
petitioner is liable for the 10-p…
IRCCourt RulingsDec 23, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
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 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 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 RulingsDec 11, 2003
…).
7
See Dunham v. Commissioner
, T.C. Memo. 1998-52.
8
See Turco v. Commissioner
, T.C. Memo. 1997-564.
9
See, e.g., Galuska v. Commissioner
, 98 T.C. 661, 668-669
(1992), affd. 5 F.3d 195 (7th Cir. 1993); Beard v. Commissioner
,
supra
at 780.
10
See Beard v. Commissioner
, supra
at 780.
11
See id.
at 773.
12
See Ecke…
IRCCourt RulingsOct 16, 2001related by meaning
hin the taxable year
in carrying on a trade or business or an activity described
in section 212 (relating to expenses for production of
income). * * * Section 164(a) does not mention Federal income taxes. On
the other hand, section 275(a)(1) provides, inter alia, that no
deduction shall be allowed for Federal income ta…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…’ d in part, vacated
in part, and remanded sub nom . JPMorgan Chase & Co. v.
Commissioner, 458 F.3d 564 (7th Cir. 2006).
For vacant, unimproved property, the comparable property sales
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 RulingsMay 9, 1988★ strong match
e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted.
An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
IRCCourt RulingsDec 2, 1981related by meaning
lowing statement: "It has been determined that you did not qualify as an organization exempt from tax under section 501 of the Internal Revenue Code.” On January 14, 1981, petitioner filed its petition herein for declaratory judgment seeking qualification of its retirement trust under sections 401 and 501 based on its …
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…iciaries:
Upon Application or Eligibility
222,680
111,340
1,855.67
54,928
Upon Renewal
17,129,262
8,564,631
142,743.85
4,225,218
Beneficiaries Living Apart
33,000
33,000
550.00
16,280
Sub-Total
17,384,942
8,708,971
145,150
4,296,426
Uniform Glossary
428,232
428,232
7,137
211,261
Notice of Modification
342,585
171,293
2…