IRCCourt RulingsAug 30, 2006related by meaning
or was the filing fee paid. See Rule 173(a). The
Court ordered petitioners to file a proper amended petition and
pay the filing fee by May 2, 2003.
13 Petitioners timely filed an amended petition with the Court
and paid the filing fee. In the amended petition, petitioners
disputed deficiencies determined for taxable ye…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
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 RulingsJan 11, 2012
…tal to the
extent of the shareholder's basis in his stock. Truesdell v.
Commissioner, 89 T.C. 1280, 1294-1295 (1987). Any amount
received in excess of both the earnings and profits of the
corporation and the shareholder's basis in his stock is treated
as gain from the sale or exchange of property. Id.
By the end of 200…
IRCCourt RulingsOct 3, 1995★ strong match
…hers. Zimmerman v. Commissioner
, 71 T.C. 367, 371 (1978),
affd. without published opinion 614 F.2d 1294 (2d Cir. 1979);
Green v. Commissioner
, 59 T.C. 456, 458 (1972). A fortiori,
explications of such publications by a Maryland State agency are
- 14 -
12
We observe that the IRS publications and the explications
there…
IRCCourt RulingsOct 25, 1999
…. See Zimmerman v.
Commissioner
, 71 T.C. 367, 371 (1978), affd. without published
opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner
, 59
T.C. 456, 458 (1972). Additionally, in order to ensure uniform
enforcement of the tax law, the Commissioner must follow
authoritative sources of Federal tax law and may cor…
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
IRCCourt RulingsAug 12, 1998
…5th Cir. 1982); see also Threlkeld v. Commissioner
, 848 F.2d
81, 84 (6th Cir. 1988), affg. 87 T.C. 1294 (1986); Propstra v.
United States
, 680 F.2d 1248, 1256-1257 (9th Cir. 1982).
(continued...)
those employees or beneficiaries. "[T]he phrase 'purposes other
than for the exclusive benefit of his employees or their
b…
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 RulingsOct 23, 2001
…Zimmerman v. Commissioner
, 71 T.C. 367,
- 6 -
371 (1978), affd. without published opinion 614 F.2d 1294 (2d
Cir. 1979). It is the relevant language of the Internal Revenue
Code which must be followed.
We find that petitioner was an active participant in an
employer pension plan and hold that, because her adjusted gros…
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 17, 1996
…ions. Zimmerman v. Commissioner
, 71 T.C. 367,
371 (1978), affd. without published opinion 614 F.2d 1294 (2d
Cir. 1979); Green v. Commissioner
, 59 T.C. 456, 458 (1972).
Publications by the IRS, like the one on which petitioner relied,
are merely guides published by the IRS to aid taxpayers. Dixon
v. United States
, 38…
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 RulingsFeb 9, 2023related by meaning
arties at the original contract date.” Notice 88-123,
1988- 2 C.B. at 477.
145
JJ. T
he 1988 amendment to section 7805 regarding temporary
regulations In 1988, Congress added section 7805(e), which provided:
SEC. 7805 (e). Temporary Regulations. --
(1) Issuance. --Any temporary regulation
issued by the Secretary shall …
IRCCourt RulingsSep 13, 1990
…ccordance with his or her fiduciary responsibilities. See Estate of Graves v. Commissioner, 92 T.C. 1294, 1302-1303↩ (1989).
IRCCourt RulingsMay 12, 2000
…. See Zimmerman v.
Commissioner
, 71 T.C. 367, 371 (1978), affd. without published
opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner
, 59
T.C. 456, 458 (1972); see also Dixon v. United States
, 381 U.S.
68, 73-75 (1965); Adler v. Commissioner
, 330 F.2d 91, 93 (9th
Cir. 1964), affg. T.C. Memo. 1963-196; Carte…
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…
IRCCourt RulingsApr 1, 2002
…rces.
Zimmerman v. Commissioner
, 71 T.C. 367, 371 (1978), affd. without
published opinion 614 F.2d 1294 (2d Cir. 1979); Green v.
Commissioner
, 59 T.C. 456, 458 (1972). Additionally, in order to
ensure uniform enforcement of the tax law, the Commissioner must
follow authoritative sources of Federal tax law and may cor…
IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
IRCCourt RulingsApr 19, 2006
…ble year. * * *
v. Commissioner
, 71 T.C. 367, 371 (1978), affd. without published
opinion 614 F.2d 1294 (2d Cir. 1979).
Second, section 72(t)(1) imposes an additional tax on
distributions from a “qualified retirement plan” equal to 10
percent of the portion of such amount that is includable in gross
income unless the …