IRCCourt RulingsJul 31, 2000★ strong match
end of that year, the
conversion credit balance was $17,643.01 ($8,603.71 + $10,530 -
$2,250.45 + $759.75); the $759.75 is the interest of 4.5 percent earned on the conversion credit balance (($17,643.01 - $759.75) x
4.5% = $759.75)). Of the conversion credit balance, $8,380.43
could have been transferred at this time …
IRCCourt RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
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 RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsOct 10, 2018
… citation of United States v.
Craft, 535 U.S. 274, 283, 288 (2002), and Notice 2003-60, 2003-2 C.B. 643, 645.
S_e_e dissenting op. p. 89. As we have explained, see supra note 25, as of the time
of the CDP hearing Mr. Melasky cannot possibly have held the Exxon Mobil stock
as a tenant by the entirety. We also do not und…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsOct 19, 1981
…ension and profit-sharing contributions. 30,600 35,500
Other deductions. 3,847 (162,483) 5,626 (187,643)
Taxable income. . 7,036 1,776
Tax. . 1,114 273
IRCCourt RulingsFeb 22, 1989related by meaning
ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
IRCCourt RulingsAug 30, 2006related by meaning
or was the filing fee paid. See Rule 173(a). The
Court ordered petitioners to file a proper amended petition and
pay the filing fee by May 2, 2003.
13 Petitioners timely filed an amended petition with the Court
and paid the filing fee. In the amended petition, petitioners
disputed deficiencies determined for taxable ye…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…,225 in subsequent years. The three-year average cost burden associated with OPM requirements is $6,643. The Departments seek comment on the assumptions and calculations made in this ICR.
Table 33—HHS Summary Cost and Burden of IDR Entity Certification Starting in 2022
Estimated number of responses
Total annual
burden
…
IRCCourt RulingsAug 10, 2015
…nd intention in engaging in the activity is to make a
profit. Dreicer v. Commissioner, 78 T.C. 642, 643 (1982), aff'd without published
opinion, 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of profit
need not be a reasonable one, but merely bona fide. Id ; sec. 1.183-2(a), Income
Tax Regs. Whether a taxpa…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…9
William Shaw V.P. Sales & 85,000 651,997 736,997
Marketing
Jim Discher Sr. Acct. Exec. 25,000 370,643 395,643
IRCCourt RulingsFeb 4, 1974
…se would lie in Commissioner v. Estate of Albright, 356 F. 2d 319 (C.A. 2, 1966), reversing 42 T.C. 643 (1964). The portion of section 2039(c) involved in the Albright case was the provision that “no exclusion shall be allowed for that portion of the value of such amount [amounts payable after death of the decedent und…
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…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…d returns showed income
as follows:
1999 2000 2001 2002 2003
Gross Income $630 ,054 $862,338 $1,990,643 $3,105,883 $2,836,896
Total Expenses 573,086 856,475 1,695,246 2,818,055 2,775,227
Net Income 56,968 5,863 295,397 287,828 61,669
For 2004, Special Agent Trogden examined the bank records of
four bank accounts titled…
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 RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCRegulationsJul 26, 2016
…'s allocable portions of the investment in the contract after adjustment for the refund feature $76,643.18 Exclusion ratio for the contract as a whole (total adjusted investment in the contract, $76,643.18, divided by the total expected return from above, $134,580.00) (percent) 56.9
IRCCourt RulingsFeb 5, 1980
…distribution which represents contribution to the trust following the loss of its exempt status ($2,643.39) is a distribution from a nonqualified plan and is ordinary income. Petitioners, citing the Second Circuit's decision in Greenwald v. Commissioner, 366 F.2d 538 (2d Cir. 1966), revg. in part 44 T.C. 137 (1965), ar…