IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsMar 31, 2005
…awable but was not paid because the employee spouse continued
to work. In re Marriage of Gillmore
, 629 P.2d 1 (Cal. 1981). As
used in this Opinion, the term “nonemployee spouse” is the spouse
with a community property interest in the retirement benefits of
IRCCourt RulingsNov 8, 1976
…ty Brands — 1972
Sammy Abraham. $23,900.00 $484.64 2.027
All other participants. 54,607.00 889.61 1.629
Beverage Sales — 1972
George Abraham. $24,000.00 $235.38 .981
All other participants. 128,681.83 814.00 .633
IRCCourt RulingsJan 28, 2002
… submitted a Form 1040, Individual Income Tax
Return, for 1998 on which he reported zero income, $5,629 in income tax withholding, and an overpayment for which he sought a
$5,629 refund. He attached to his Form 1040 a signed statement
consisting of two typewritten pages in which he made various
arguments denying his du…
IRCCourt RulingsAug 3, 1987
…urnetta, O.D., P.A. v. Commissioner, 68 T.C. 387, 397 (1977); Packard v. Commissioner, 63 T.C. 621, 629 (1975). Sec. 31.3121(d)-l(c)(2), Employment Tax Regs., defines the common law employer-employee relationship as follows:
IRCCourt RulingsNov 21, 2007
…ation, on behalf
of Norwest Bank MN NA IRA C/F Ramzy Kopty reporting rollover
contributions of $411,629 .63 for 1998 . According to that form,
the fair market value of petitioner's IRA account was
$337,854 .33 .
During 1999, petitioner's IRA earned dividend income in the
aggregate amount of $6,093 .21 . During the year…
IRCCourt RulingsAug 30, 1999related by meaning
tions in his gross income for 1995.
The only exception to section 408(d)(1) that might apply in
the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The
transfer of an individual's interest in an individual
retirement account or an individual retirement annuity
to his spo…
IRCCourt RulingsJun 10, 1996
Id.
at 629. We stated: "Our
conclusion that there was only a technical change in the
employment relationship is supported by the fact that Dr. Burton continued performing the same services as a sole proprietor as he
had performed in the corporate form." Id.
at 629-630; see also
Reinhardt v. Commissioner
, supra
(chang…
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…
IRCCourt RulingsOct 17, 1995
…400.00 -0- -0- -0Federal Express 14.00 -0- -0- -0Miscellaneous -0- 14.00 -0- 14.00
Pool service -0- 629.50 -0- 629.50
12
Depreciation 14,969.00
296.00
296.00
-0-
Total 28,939.91
7,147.83
4,591.86
2,555.97
The Charleston Property: 1989
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCFinal Rules (FR)Oct 8, 2019
…e been expected to sell for $445,152 in December 2011, according to the Case-Shiller Index and $414,629 according to the FHFA Index.
Table 1—House Price and Inflation Adjustments of $250,000 at June 30, 1994, for the Case-Shiller Index and the FHFA Index, and July 1, 1994 for the CPI Index
Table 1
year
Case-Shiller
FHF…
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 RulingsMar 24, 1980
… Mr. Carter Mr. Horner
1958 $12,955
1959 18,460
1960 20,732
1961 22,766
1962 27,467
1963 31,149 $18,629
1964 31,048 18,629
1965 42,064 31,138
1966 45,652 42,522
1967 85,659 66,125
1968 114,084 78,229 $26,111
1969 204,775 163,292 33,249
1970 331,196 265,829 45,276
Although the nondef erred compensation paid to the offic…
IRCCourt RulingsApr 14, 2005
…); Simpson v. Commissioner
,
- 16 -
64 T.C. 974, 984 (1975); Packard v. Commissioner
, 63 T.C. 621,
629 (1975); sec. 1.1402(c)-1, Income Tax Regs.
Relevant factors courts consider to determine whether an
employer/employee relationship exists between the service
provider and the hiring party include: (1) The hiring part…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
75 FR 5410 — Interim Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 IRCFinal Rules (FR)Feb 2, 2010
…elve month use of mental health services in the United States.”
Archives of General Psychiatry,
62, 629-640. The study found that 40 percent of people reporting mental health and substance use disorders receive some treatment in a year.
Back to Citation
27.
Wang, P.S., Lane, M., Olfson, M., Pincus, H.A., Wells, K.B., …
IRCPrivate Letter RulingsSep 12, 2014
…ress below:
Internal Revenue Service
Manager, Actuarial Group 2
1111 Constitution Avenue, N.W. (NCA-629)
Washington,
DC 20224
If any one of the conditions written in Letter Ruling, as modified by this letter, is not
satisfied, the approval to extend the amortization periods for amortizing the unfunded
liabilities would…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsMar 6, 2001★ strong match
…and Trust Co. v. United States
, 421 F.2d 475 (6th
Cir. 1970); Geurkink v. United States
, 354 F.2d 629 (7th Cir.
1965); Luhring v. Glotzbach
, 304 F.2d 560 (4th Cir. 1962);
Collins v. Commissioner
, supra
; Notaro v. United States
, 71 AFTR
2d 93-659, 93-1 USTC par. 50,030 (N.D. Ill. 1992); First Fed.
Sav. & Loan Asso…