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90 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…
  2. 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 …
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  5. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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
  7. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  8. 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. …
  9. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  10. Treas. Reg. § 1.417(a)(3)-1(e) — Required explanation of qualified joint and survivor annuity and qualified preretirement survivor annuity.
    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 …
  11. 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…
  12. 90 FR 60432 — Transparency in Coverage
    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…
  13. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    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…
  14. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  15. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    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.
  16. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    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…
  17. 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,…
  18. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    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…
  19. 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 …
  20. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    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…