IRCCourt RulingsFeb 9, 2023related by meaning
Decision 5426 does not appear to be relevant to the dispute in L.E.
S hunk Latex . Indeed, because the regulatory amendments of Treasury Decision 5426 merely mirrored changes made to the relevant statute, it would appear that even a
dispute implicating the text of the regulatory amendments of Treasury Decision 5426
wou…
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
IRCCourt RulingsJun 17, 1997
…ncome 232,158 382,445 351,722 106,927 96,476
Taxes 10,306-0-13,572-0-7,519
Fiduciary fees 53,836 63,293 22,994-0 - - 0 -
Attorney, accountant 13,247 136,440 96,205 104,764 173,804
Other deductions 3,500-0-16 1,761 10,547
Other deductions: mgmt/admin fees-0 - - 0-173,550 79,263 128,000
Exemption 100 100 100 100 100
Taxa…
IRCRegulationsSep 9, 2016
…rial present value of $498,089, while the single-sum payment has an actuarial present value of $224,293 (i.e. the amount of the single sum is $224,293) and that the single life annuity is approximately equal in value to the QJSA. The explanation states that the relative value comparison converts the value of single lif…
IRCCourt RulingsJan 17, 2024related by meaning
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…
IRCCourt RulingsAug 6, 1997★ strong match
…ons To Tax
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6654(a)
- 2 -
1992 $13,005 $3,251 $457
1993 5,172 1,293 217
Susan W. Cujas
Additions To Tax
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6654(a)
1992 $4,528 $1,132 $127
1993 5,172 1,293 217
All section references are to the Internal Revenue Code in
effect for the years in issue, …
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 RulingsJul 14, 2005★ strong match
…h
the great remedial purposes of the legislation
creating" the U.S. Tax Court. Helvering v. Taylor, 293
U.S. 507, 516 (1935).
* * * * * * *
In many, but not all cases, evidence adequate to
overthrow the Commissioner's findings is also adequate
to show the correct amount that is due. Id. [Helvering
v. Taylor, 293 U.S. 5…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…nk v . Commissioner , 369 U .S .
672, 686 (1962) ; Maadalin v . Commissioner ,' -T .C . Memo . 2008-293
n .7 .
- .10 -
Minors Act is treated as held by the disabled person or child
.
Petitioner's other argument is that an IRA is a grantor trust
that qualifies as an S corporation shareholder under section
1361(c)(2)(A)(…
IRCRegulationsSep 9, 2016
… B, when the age-adjusted section 415(b)(1)(A) dollar limit for benefits commencing at that age is $293,453. (ii) Conclusion.
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
IRCCourt RulingsJan 12, 2004
…es deductions for such taxable year).”
Respondent did not question petitioner’s claim that
- 4 -
$3,293.20 of the $6,700.00 distribution was for qualified medical
expenses and was an exception to the 10-percent additional tax
due to early distribution. In that regard, petitioner claimed a
standard deduction of $4,300 o…
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
82 FR 46388 — Mortality Tables for Determining Present Value Under Defined Benefit Pension Plans IRCFinal Rules (FR)Oct 5, 2017
…4,356 million
Estimated change in PBGC premiums (in millions of 2017 dollars)
Full take-up amount
0
293
287
187
91
0
0
0
0
81
No take-up amount
293
287
280
183
89
0
0
0
0
80
Present Value with full take-up of delay option (3% Discount Rate): 869 million
Present Value with no take-up of delay option (3% Discount Rate): …
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o… IRCRevenue RulingsSep 8, 2014
…he requirements of Rev. Rul. 2011–1, 2011–2 I.R.B. 251, as modified by Notice 2012–6, 2012–3 I.R.B. 293, to include trusts of certain retirement plans qualified only under the Puerto Rico Code (Código de Rentas Internas para un Nuevo Puerto Rico de la Ley Núm. 1 de 31 de enero de 2011) and clarifies that assets held by…
PLR 201650003 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsDec 9, 2016
…modified by Rev. Rul. 2011-1, 2011-2 I.R.B. 251 (which
was modified by Notice 2012-6, 2012-3 I.R.B. 293) (an “81-100 group trust”). The ruling
specifi es that Taxpayer is exempt from federal income tax (i) under Internal Revenue
Code (“Code”) section 501(a) for the funds that equitably belong to its participating
trust…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
… cause
defense is not available. See § 6664(c)(3); see also Chandler v.
Commissioner, 142 T.C. 279, 293 (2014).
B. Constitutional Challenge to Section 6662 Penalty
Petitioner disputes the constitutionality of the accuracy-related
penalty under section 6662 in the light of the U.S. Supreme Court’s
decision in SEC v. Jar…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…