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82 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    of the $5,104,756 trademark royalty payment can be viewed as a $0 adjustment because respondent agrees with the tax reporting of this amount by the 3M consolidated group. Equivalently, one can think of respondent’s position on the tax treatment of the $ 5,104,756 trademark royalty payment as comprising two separate ste…
  2. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    … owned a 22.5-percent interest in America/Bradley and had a deficit capital account balance of $448,756 as of January 1, 1987. The total of all America/Bradley partners' capital accounts decreased from a deficit of $996,674 at the beginning of 1987 to a deficit of $2,853,708 at the end of
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  4. T.C. Memo. 2002-30 — Drew Allen Rayner v. Commissioner
    IRCCourt RulingsJan 28, 2002
    …state that he received in 1998 retirement account distributions totaling $217,331.44, of which $214,756.96 is taxable. B. Petitioner’s 1998 Income Tax Return Petitioner submitted a Form 1040, Individual Income Tax Return, for 1998 on which he reported zero income, $5,629 in
  5. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  6. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …3,060 3,060 3,060 --- Depreciation/sec. 179 expense 36,179 36,179 --- 36,179 Car and truck expenses 756 756 --- 756 Advertising 435 435 435 --- Repairs and maintenance 71 71 71 --- i. Wages On brief respondent concedes that petitioners have substantiated BJWrelated wages of $65,208, leaving the remaining $3,478 at issu…
  7. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    … hours drafting an authorization form for IRA holders to sign. This results in an hour burden of 17,756 hours with an equivalent cost of $2.9 million.[70] The Department expects that Plans and IRAs will send the written authorization through already established electronic means, and thus, the Department does not expect…
  8. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    … each of the years 1992 through and including 1997 : Year Shares Value Cash Tota l 1992 20 .3100 $3,756 .70 ($57 .43) $3,699 .2 7 1993 36 .1085 6,818 .47 1,608 .94 8,427 .4 1 1994 66 .0084 15,698 .12 1,725 .72 17,423 .8 4 1995 108 .1071 46,776 .86 6 .29 46,783 .1 5 1996 144 .5164 108,732 .69 30 .90 108,763 .5 9 1996 11…
  9. IRCCourt RulingsAug 3, 1979related by meaning
    istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
  10. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    s any proceedings before us. The mere fact that petitioners are defending the position that was advertised to them in connection with their investment in the subject VEBA’s is insufficient grounds to penalize each petitioner under the facts herein. Petitioners are not directly responsible for most of the actions listed…
  12. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  13. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    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…
  14. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007
    …esent litigation. Expense item Monthly expense Food, clothing, misc. $1,005 Housing and utilities 1,756 Transportation 307 Health care 533 Taxes (income and FICA) 707 Life insurance 121 Other secured debt 460 Other expenses 458 Total 5,347 Petitioners did not explain the “other secured debt” or “other expenses”. 7 In t…
  15. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    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…
  16. Rev. Rul. 2003-83 — Minimum funding; entry age normal; reasonableness. This ruling addresses two situations where the aggregate entry age normal method of funding is not a reasona…
    IRCRevenue RulingsJul 28, 2003
    …ntil the participant's retirement age is 166.1594. Accordingly, the normal cost per participant is $756.21 ($125,651.72 divided by 166.1594), and the normal cost for the plan is $756.21 × 20 (the number of participants), or $15,124.24. The present value of projected benefits (as of January 1, 2003) is $587,169.50 and t…
  17. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    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…
  18. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    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,…
  19. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  20. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan. Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…