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, 2018★ strong match
…sioner, 909 F.2d 1360 (9th Cir. 1990), aff'g in part,
rev'g in part Larsen v. Commissioner, 89 T.C. 1229 (1987), and aff'g Casebeer v.
Commissioner, T.C. Memo. 1987-628, Moore v. Commissioner, T.C. Memo.
1987-626, and Sturm v. Commissioner, T.C. Memo. 1987-625. See Sacks v.
Commissioner, 69 F.3d at 988 ("Our analytic t…
IRCCourt RulingsFeb 9, 2023related by meaning
owing
differences:
I --between the amounts of royalties and other
expenses referred to in article 74 of the
mentioned Law, credited or paid during the base-year, and the minimum percentages
established for the respective deduction,
according to (b) and (d);
II--between the quotas for the purpose of
forming depreciation…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…nerally the most reliable method of valuation.” Estate of
25
Spruill v. Commissioner, 88 T.C. 1197, 1229 n.24 (1987) (quoting Estate
of Rabe v. Commissioner, T.C. Memo. 1975-26, aff ’ d , 566 F.2d 1183 (9th
Cir. 1977) (unpublished table decision)) . The comparable property sales
method determines fair market value by c…
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…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
IRCPrivate Letter RulingsDec 1, 2006
…kin v. Commissioner
, 125 F. 3
rd
339, 342-343 (6
th
Cir.
1 997); Marcus v. DeWitt
, 704 F.2d 1227, 1229-30 (11
th
Cir. 1983). Accordingly, an
attorney’s fee that does satisfy the requirements of the regulations is not deductible as an
administration expense e ven if it is approved by a local court as an expense payabl…
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 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 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…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
80 FR 72006 — Savings Arrangements Established by States for Non-Governmental Employees ERISAProposed Rules (FR)Proposed Nov 18, 2015
…was automatic rather than voluntary”);
cf. The Meadows
v.
Employers Health Ins.,
826 F. Supp. 1225, 1229 (D. Ariz. 1993) (enrollment not “completely voluntary” where health insurance contract required 75 percent of employees to participate);
Davis
v.
Liberty Mut. Ins. Co.,
Civ. A. No. 87-2851, 1987 WL 16837, *2 (D.D.C.…
IRCCourt RulingsApr 23, 1979
…ations in which two formally separate contracts are treated as one. Kess v. United States, 451 F.2d 1229, 1231 (6th Cir. 1971); Estate of Montgomery v. Commissioner, 56 T.C. 489, 496-497 (1971), affd. 458 F.2d 616 (5th Cir. 1972), cert. denied 409 U.S. 849 (1972). Conversely, we recognize one document may embody two co…
IRCCourt RulingsNov 1, 2005related by meaning
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 RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsJun 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCourt RulingsAug 30, 1999related by meaning
eives any amount from a qualified retirement
plan (as defined in section 4974(c)), the taxpayer's
tax under this chapter for the taxable year in which such amount is received shall be increased by an amount
equal to 10 percent of the portion of such amount which
is includible in gross income.
A "qualified retirement pl…