IRCCourt RulingsFeb 12, 2014
…96,230,
and Mr. Black's investment in the contract (in the form of aggregate premiums
paid) was $86,663.
Northwestern issued to Mr. Black a Form 1099-R, Distributions From
Pensions, Annuities, Retirement Or Profit-Sharing Plans, IRAs, Insurance
Contracts, Etc., for 2009 reflecting a gross distribution of $196,230 and a…
IRCCourt RulingsMar 5, 2018related by meaning
ximum of 46% of the combined income to the FSC (by adjusting the sale 1
transfer price). If the profit margin was between 3.98% and 7.96%, the maximum amount of taxable income assignable varied inversely from 46% to 23%,
respectively. If the profit margin exceeded 7.96%, they could assign a maximum
of 23% of the combin…
IRCCourt RulingsOct 20, 1998
…800 in taxable
pension income, and a $7,140 loss from rental real estate, for a
total income of $61,663. Petitioner claimed a $2,000 deduction
for a contribution to an IRA and an $8,000 deduction for alimony
paid, resulting in an adjusted gross income of $51,663.
In the notice of deficiency, respondent determined that
…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsFeb 28, 2024related by meaning
8
years on June 10, 2016. That notice was issued timely because, as of
3
The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
IRCCourt RulingsOct 10, 2018
…rposeful, and intentional interference.2
¹See Cox v. Mortg. Elec. Registration Sys., Inc., 685 F.3d 663, 671 (8th Cir.
2012) (holding that the plaintiff had not sufficiently pleaded the defendant's
breach of its "duty of good faith and fair dealing by unjustified hindrance" of
contract performance); In re Econ. Lodging…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
… Equity Acquisitions of Physician Medical Groups across Specialties, 2013-2016.” 323
JAMA
7 (2020): 663-665.
Back to Citation
113.
Zhu, Jane M., Lynn M. Hua, and Daniel Polsky. “Private Equity Acquisitions of Physician Medical Groups across Specialties, 2013-2016.” 323
JAMA
7 (2020): 663-665.
Back to Citation
114.
Ko…
IRCCourt RulingsOct 10, 1979related by meaning
es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
IRCCourt RulingsDec 2, 2010related by meaning
bility for income tax for
2004 that exceeded $1,000, net of any section 31 credit, and has
taken judicial notice of the fact that petitioner had a tax liability in 2003. Therefore, the Court sustains respondent's
determination of the addition to tax pursuant to section 6654(a).
The Court has considered all of petitione…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…articipating provider at a participating facility,[185] the Departments estimate that approximately 663,436 individuals will have the potential to be treated by a nonparticipating provider or facility. In the absence of data, the Departments assume that in 50 percent of cases services will be provided by nonparticipati…
IRCPrivate Letter RulingsJul 31, 2009
…. Such accounts must be sufficiently separate and
independent to qualify as separate shares under § 663(c). The general test for separate and indepe ndent
shares under § 663(c) is “whether distributions of the trust are to be made in substantially the same
ma nner as if separate trusts had been created.” Treas. Reg. § …
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCCourt RulingsJun 17, 1997
…1992
1993
1994
Total
DWB's (number) 0
6
50
57
87
56
256
Withdrawal dist. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536
DWB's (amount) 0
11,985
682,394
640,125
727,947
671,783
2,734,234
Total 468,274
2,304,351
4,531,057
11,372,646
6,954,975
4,789,467
30,420,770
B. Suspense Account transact…
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
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 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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…stion of fact to be resolved on the basis of the entire
record. See Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). Because
there is rarely a substantial market for sales of easements comparable
to the donated easement , courts typically value conservation easements
indirectly using a “before and after” approach . See…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
… question of fact to be resolved on
the basis of the entire record. Kaplan v. Commissioner, 43 T.C. 663, 665
(1965).
To support their positions regarding valuation, the parties
retained experts. We assess an expert ’ s opinion in the light of the
expert’s qualifications and the evidence in the record. See Parker v.
Com…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
Treas. Reg. § 1.404(a)-12(b)(3) — Contributions of an employer under a plan that does not meet the requirements of section 401(a); application of section 404(a)(5). IRCRegulationsMay 18, 2016
… accounts must be sufficiently separate and independent to qualify as separate shares under section 663(c). Nothing shall preclude a trust which loses its exemption under section 501(a) from setting up such acounts and meeting the separate account requirement of section 404(a)(5) with respect to the taxable years in wh…