IRCCourt RulingsMay 19, 2011
…ngly, we sustain respondent's
determination that Weekend Warrior has forgone interest income of
$39,896 and $71,680 for 2002 and 2003, respectively.
The foregoing c¯onclusion results in the corollary conclusion
that in 2002 Mr. Warmoth had constructive dividend income of
$39,896." Petitioners do not rely on any facts o…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976★ strong match
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 …
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
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 RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsJan 14, 2013
… 1,169,540 22,903 18,346 41,249
1998 1,238,596 44,632 30,033 74,665
1999 1,265,554 81,916 12,980 94,896
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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…at the quid was adoption services provided by
33
[* 33] the donee); DeJong v. Commissioner, 36 T.C. 896, 899 – 900 (1961)
( determining that the quid was education services provided by the
donee), aff ’ d , 309 F.2d 373 (9th Cir. 1962). Nor did the Board of
Supervisors compel the donation to a donee of its choice. Cf. …
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…
IRCRegulationsSep 9, 2016
…rmined using the 5.5 percent interest and the section 417(e)(3) applicable mortality table) is $498,896 and the actuarial present value of the single life annuity is $497,876. Accordingly, the specific information discloses that the single-sum distribution has a value that is 45 percent of the value of the single life …
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…5
30
1,307,700
167.48
219,013,596
Plan MEWAs that are not fully insured
132
15
60
118,800
167.48
19,896,624
Non-plan MEWAs that are not fully insured
21
15
60
18,900
167.48
3,165,372
First-year Total
10,021
15
5,877,000
984,279,960
Subsequent Years
Issuers (health insurance company/State combinations)
1,467
15
12
264,0…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… Matthew A. Unruh, et al.,
Physician Turnover in the United States,
175 Annals of Internal Medicine 896, 903 (2023).
Back to Citation
152.
See Table 3 for an example.
Back to Citation
153.
For the purposes of this section III.C.11, the term “health insurance market” refers to the definition in proposed 25 CFR 54.9815…
IRCCourt RulingsJun 13, 2017
…t year-end 2009 and 2010 Petersen had accrued but unpaid vacation pay expenses of $473,744 and $503,896, respectively. These amounts were
paid to its employees by December 31 of the following year. Roughly 94.5% of
these amounts was attributable to employees who participated in the ESOP.3
Petersen filed timely Forms 11…
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 RulingsJun 6, 2019
…ssioner, 58 T.C. 256, 259 (1972); see also sec.
6213(a); Estate of Cerrito v. Commissioner, 73 T.C. 896 (1980).
- 5 -
[*5] Petitioner's offer-in-compromise (OIC) was sent to the IRS Appeals Office
(Appeals) for consideration by an Appeals officer.
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…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
… J. Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
498,812 896,239 1,225,134 1,454,591
L. Account limit (yearend)
5
8,056,566 14,031,392 20,657,080 28,881,609
M. Actual contribution 30,689,717 2,170,000 13,966,816 12,247,933
N. Value of assets (yearend) 30,736,554 30,176,217 39,…
IRCCourt RulingsDec 30, 1998related by meaning
of these funds since they
were originally invested in the Fortis annuity contract in 1992.
We conclude that petitioner's direct exchange of a portion of her Fortis annuity contract for a new Equitable annuity
contract qualifies under section 1035 and that no gain to
petitioner is to be recognized by reason of the exch…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…and fraud penalties pursuant to section 6663
1
as follows:
Year Deficiency § 6663 Penalty
1999 $ 72,896 $54,672.00
2000 92,891 69,668.25
1
Unless otherwise indicated, statutory references are to the Internal Revenue
Code, Title 26 U.S.C. (Code), in effect at all relevant times, regulation references are
to the Code of …
IRCCourt RulingsNov 25, 2002
… 4 -
3
“Section 8” is a reference to sec. 8 of the United States
Housing Authority Act of 1937, ch. 896, 80 Stat. 888, as amended
by the Housing and Community Development Act of 1974, Pub. L. 93383, sec. 201(a), 88 Stat. 662, which is codified as 42 U.S.C.
sec. 1437f (2000). Generally, “Section 8” refers to assisted
pu…