IRCCourt RulingsFeb 6, 2024★ strong match
…itioner constructively received
and must include in his gross income a taxable distribution of $427,518
IRCCourt RulingsApr 22, 2003
ed by PCB that shows Federal
income tax withheld of $2,518. What petitioner did was to claim
a deduction and a withholding credit for the same $2,518. Petitioner properly reported the amount as Federal income tax
withheld. The Court concurs in respondent's determination that
the deduction of the $2,518 as an amount for…
IRCCourt RulingsJul 13, 1995★ strong match
… earnings, and may even have paid substantial dividends to shareholders. * * *
[S. Rept. 99-313, at 518-519 (1986), 1986-3 C.B. (Vol. 3) 1, 518-519.]
Based on the above rationale, Congress revamped the AMT provisions to include corporate taxpayers and promulgated a series of highly technical provisions designed to mirr…
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
ary 1, 1992. As a
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12
SFAS 106, par. 518, defines an “unrecognized transition
obligation” as the unrecognized amount, as of the date SFAS 106 is initially applied, of “(a) the accumulated post-retirement benefit
obligation in excess of (b) the fair va lue of plan assets plus
accrued post-retirement benefit cost o…
IRCCourt RulingsFeb 28, 2024
… the Motion and not as findings
of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518,
520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994). Petitioner resided in
Washington when he petitioned this Court. Absent stipulation to the
contrary, appeal of this case would apparently lie to the U.S. Court of
Appe…
IRCCourt RulingsJun 10, 1996related by meaning
mount necessary to fund the
benefits payable under section 415 determined at the time of the
contribution in question. Citrus Valley Estates, Inc. v
. Commissioner
, 99 T.C. at 447. The dispute in these cases focuses
on the amounts of benefits payable under section 415 determined
at the time of the contributions in que…
T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov… IRCTreasury DecisionsAug 15, 2016related by meaning
ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred.
EMPLOYEE PLANS
T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…nual cost is estimated as: ($1,340,036 to maintain records + $3,178,800 to distribute records) = $4,518,836.
Back to Citation
536. The first-year total cost includes: ($1,671,795 for rule review + $9,355,525 for general disclosures + $201,597 for policies and procedures + $2,359,860 for the retrospective review + $4,5…
IRCCourt RulingsJan 17, 2024related by meaning
… the Motion and not as findings of fact in this case. See
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this
case would apparently lie to the U.S. Court of Appe…
IRCCourt RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979related by meaning
n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
IRCCourt RulingsNov 1, 2005★ strong match
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
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
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imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCPrivate Letter RulingsMar 2, 2001
….
ISSUE
5. In light of the Supreme Court’s decision in Reorganized CF&I Fabricators of Utah, Inc. , 518 U.S. 2131 (1996), would a bankruptcy f iling by
Company A raise a substantial hazard that pre-petition, unassessed excise taxes
under §§4975(a) and (b) w ill be classified as penalties, such that they are treated
as …
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…
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
…, NW., Washington, DC 20429.
NCUA:
John Brolin, Staff Attorney, Office of General Counsel, at (703) 518-6540, or Vincent Vieten, Program Officer, Office of Examination and Insurance, at (703) 518-6360, or 1775 Duke Street, Alexandria, Virginia, 22314.
Bureau:
Owen Bonheimer, Counsel, or William W. Matchneer, Senior Cou…
IRCCourt RulingsMar 9, 2011★ strong match
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal IRCProposed Rules (FR)Proposed Aug 8, 2013
… Staff Attorneys, or Frank Kressman, Associate General Counsel, Office of General Counsel, at (703) 518-6540, or Vincent Vieten, Program Officer, Office of Examination and Insurance, at (703) 518-6360, or 1775 Duke Street, Alexandria, Virginia, 22314.
OCC:
Robert L. Parson, Appraisal Policy Specialist, (202) 649-6423, …