IRCCourt RulingsAug 31, 1964
OPINION
'Scott, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year 1960 in the amount of $9,125 and an addition to the tax under section 6654 of the Internal Revenue Code of 1954 for underpayment of estimated tax in the amount of $83.95.
The two issues raised by the pleading…
IRCCourt RulingsJul 11, 2024
…g 2016 . A gain
a s with 2015, Mrs. Tuma’s 2016 Form 1099– R reported a gross
distribution of $16 , 993 and characterized the entire amount as taxable.
6
[* 6 ] III. Petitioners’ Income Tax Reporting
Petitioners jointly filed a Form 1040, U.S. Individual Income Tax
Return , for each year in issue . Mr. Tuma prepared th…
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…333,233 × 8% = 26,659.
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296. The burden is estimated as follows: 26,659 × 90% = 23,993 uninsured (or self-pay) individuals will self-represent. 23,993 × 2 hours = 47,986 hours. A labor rate of $64.32 is used for uninsured (or self-pay) individuals (all occupations). The labor rate is applied in the fol…
IRCCourt RulingsFeb 4, 1998related by meaning
exceptions contained
therein. See Recklitis v. Commissioner
, 91 T.C. 874, 913 (1988);
Tillman v. Commissioner
, T.C. Memo. 1996-8. Because petitioner has not shown that any one of the exceptions applies, we sustain
respondent's determination on this issue.
IV. Section 6673--Penalty Awarded by Court
We decide sua spont…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
IRCRegulationsSep 9, 2016
akes a contribution of $9,993 on April 10, 2016. The effective interest rate for Plan F for the 2016 plan year is 5.90%. (ii) In accordance with paragraph (c)(3)(ii) of this section, the contribution is increased for interest at the effective interest rate, for the 5 days between the contribution date and the due date …
IRCCourt RulingsAug 22, 2002
…r
education expenses for that year.
In the present case, petitioner explained that she withdrew
$41,993 from her qualified retirement account because she
required funds to buy a car and to pay off bills in addition to
paying amounts to the University of Phoenix during 1998. On this
record it is clear that petitioner di…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsFeb 9, 2023related by meaning
gross income, deductions, credits, or allowances
between or among such organizations, trades, or
businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to
prevent evasion of taxes or clearly to reflect the income of
any of such organizations, trades, or businesses. In t…
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
IRCCourt RulingsMay 20, 1976
70. On November 30, 1970, the corporation deposited the sum of $16,993.41 in the trust account at Bankers Trust Co. for the pension plan contribution. On February 18, 1971, the corporation filed its initial income tax return (Form 1120-S, U.S. Small Business Corporation Income Tax Return) for the taxable year November …
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024★ strong match
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
regulations at 31 CFR Chapter X.
See 31 CFR 1010.100(e).
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2.
31 U.S.C. 5311.
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3.
31 U.S.C. 5318.
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4. Treasury Order 180-01 (Jul. 1, 2014).
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5.
31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section …
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024related by meaning
U.S.C. 987, 989, and 6001.
Section 1.987-11 also issued under 26 U.S.C. 987, 989, and 1502.
Section 1.987-12 also issued under 26 U.S.C. 987 and 989. Section 1.987-13 also issued under 26 U.S.C. 987 and 989.
Section 1.987-14 also issued under 26 U.S.C. 987 and 989.
Section 1.987-15 also issued under 26 U.S.C. 987 and …
IRCCourt RulingsJan 2, 2020related by meaning
principles and to deter the waste of judicial resources. See Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of
the potential implications of continuing to assert frivolous and groundless
arguments. For…
Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex… IRCNoticesNov 13, 2007related by meaning
g whether an estate making the section 6166 election will be required to provide security.
TAX CONVENTIONS
Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…