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 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 RulingsJul 5, 2011
…inte est. Swanson v. Commissioner, T-.C. Memo. 200931 (citing LaVerne v. Commissioner, 94 T.C. 637, 652-653 -(1990),
affd. without pu lished opinion 956 F.2d 274 (9th Cir. 1992));
see Hansen v. Commissioner, 471 F.3d 1021, 1031 (9th Cir. 2006),
85 FR 27693 — Effect of Section 67(g) on Trusts and Estates IRCProposed Rules (FR)Proposed May 11, 2020
…eductions, Credit, etc. The proposed regulations adopt the suggestion that the principles under § 1.652(b)-3 be used to allocate each item of deduction among the classes of income in the year of termination for purposes of determining the character and amount of the excess deductions under section 642(h)(2). Section 1.…
85 FR 66219 — Effect of Section 67(g) on Trusts and Estates IRCFinal Rules (FR)Oct 19, 2020
…s determined by allocating the deductions among the estate's items of income as provided under § 1.652(b)-3. Under § 1.652(b)-3(a), the $2,000 of rental real estate expenses is allocated to the $2,000 of rental income. In the exercise of the executor's discretion pursuant to § 1.652(b)-3(b), D's executor allocates $…
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 RulingsApr 5, 2022
…ut
claiming it emi zed deductions for the following expenses :
Item Amount
State and local taxes $1,652
Home mortgage interest 10, 65 2
Mortgage insurance premiums 1, 091
Charitable contributions 2,816
Unreimbursed employee expenses ,
including vehicle costs
10, 4 55
Miscellaneous other deductions 3 80
On this Form 104…
IRCCourt RulingsJul 22, 1980related by meaning
have become available to petitioner to act upon the trust instrument’s contingency language. However, we need not decide petitioner’s right under art. VIII to convert the $16,123 to any purpose it deemed appropriate, since, despite the provision, the facts here failed to show any vesting of any funds to employees in 19…
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…
IRCCourt RulingsSep 28, 1983
…nts break down into the following categories:
1975 1976 1977 Novelties $2,406,914 $2,997,737 $4,210,652
Page receipts 232,053 236,737 216,703
Strip receipts . 269,407 274,895 319,991
Publishing $380,137 $298,218 $358,233
Miscellaneous 405 89 1,020
Pursuant to the marriage settlement agreement, petitioner received $777,…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…or federal income tax purposes; or (3) petitioners’
income should be increased pursuant to sections 652(a) and 662(a). Because the Court
finds that the trusts were shams without economic substance, the Court does not
address those alternative positions.
18
[* 18] The beneficiary is taxed on amounts received from a trus…
IRCCourt RulingsFeb 22, 1989
…ontribution. La.R.S. 42:651B. When the employee contributions are received by the board, La.R.S. 42:652 requires that they be credited to the Employees’ Savings Account. La.R.S. 42:653 requires that the employer contributions be credited to the Employer’s Accumulation Account. When the member retires, his or her accumu…
IRCFinal Rules (FR)Aug 26, 2022
…nt will be accounted for by Department of the Treasury. Thus, HHS will account for approximately 42,652 hours with an equivalent cost of approximately $2,164,990. DOL and the Department of the Treasury will each account for approximately 21,326 hours with an equivalent cost of approximately $1,082,495.
Table 2—Summary …
IRCCourt RulingsAug 12, 1998★ strong match
…mmissioner
, T.C. Memo. 1994-606; see
also Calfee, Halter & Griswold v. Commissioner
, 88 T.C. 641, 652
(1987) ("the standards of Title I and Title II [of ERISA] were
closely coordinated by Congress specifically to develop a unified
set of rules").
- 31 -
The DOL regulations state that a fiduciary will satisfy the
prud…
IRCCourt RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
IRCCourt RulingsFeb 4, 1974★ strong match
be communicated to Participant by the Committee to the Trustee, and the Trustee upon receipt thereof, shall adopt such selection and comply therewith. 3. If the employment of any Participant is terminated and Participant is reemployed by the Corporation or the Subsidiary, he shall be deemed under all provisions of this…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCCourt RulingsMar 1, 1999related by meaning
me-generating activities
relating to the items of income, he has satisfied that obligation
through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation
should have been divided between himself and his spouse, there is
no basis for making any apportionment. …