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75 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    …56,000 Based on the evidence before us, we conclude that petitioner's tax basis in her home is $277,633, or $56,000 over the $221,633 allowed by respondent. - 14 - Miscellaneous Itemized Deductions With respect to the claimed $1,000 consulting fee in excess
  2. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ould have appeared in the Termination Agreement was $2,135,260), and that MPC offered to pay $1,899,633. MPC proposed to do so by transferring to MIT 83 the note made by Qulart on July 1, 1983, in favor of Machise in the amount of $2,888,666. The balance on the note as of January 1, 1988, was $1,899,633. MIT 83 accepte…
  3. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    Cumulative Difference -0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji 1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3 Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…
  4. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  5. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    … upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni was aware that Mrs. Gurule and petitioners' middle son suffered from severe medical conditions that left them with high med…
  6. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    …o. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes
  7. 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…
  8. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …source of information in a deficiency case such as this one. See Wilkinson v. Commissioner, 71 T.C. 633, 639 ( 1979). 48 During 2006, 3M Brazil paid $52,522,080 in dividends and $11,978,720 in interest on net equ ity to 3M IPC. The total of these payments is $64,500,800. In 2006, 3M Brazil made no payments to 3M Compan…
  9. 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…
  10. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012
    …16,392 16,392 Amount Amount Expenses claimed determined Food, clothing, and miscellaneous $1,250 $1,633 Housing and utilities . 6,279 2,519 Vehicle operating costs 650 650 Public transportation 362 182 Health insurance 480 480 Out-of-pocket health costs 150 300 Court-ordered payments 633 633 Life insurance 400 400 Taxe…
  11. 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…
  12. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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 …
  13. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995
    …o. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 1357-1358 (D. Md. 1984). 4 So stipulated.
  14. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  15. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  16. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …imum Petitioner Respondent 2002 $160,000 $69,740 $52,935 2003 160,000 69,687 53,150 2004 165,000 71,633 54,811 2005 170,000 74,170 56,472 2006 175,000 76,352 58,133 In view of his computation pursuant to section 415(b)(2)(C) of lower reduced benefit limits, respondent in the notice of deficiency further calculated allo…
  17. Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”…
    IRCRevenue ProceduresOct 15, 2018
    …failures 632 .03 Effect of VCP submission on examination 632 .04 No concurrent examination activity 633 .05 Determination letter applications not related to a VCP submission 633 .06 Processing of submission 633 .07 Compliance statement 634 .08 Effect of compliance statement on examination 635 .09 Special rules relating…
  18. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …(c) (4) superfluous. See sec. 402(i); Weinberger v. Hynson, Westcott & Dunning, Inc., 412 U.S. 609, 633 (1973) (an interpretation that renders a statutory provision superfluous
  19. 89 T.C. 939; 89 T.C. No. 65 — Estate of Neisen v. Commissioner
    IRCCourt RulingsOct 28, 1987
    of deficiency, respondent determined that petitioner was entitled to a marital deduction of only $ 633,532.39, stating, in relevant part, as follows: The $ 1,015,207.14 shown as a marital deduction is reduced by $ 381,674.75 because the interest passing to the surviving spouse is determined by a formula marital deduct…
  20. Treas. Reg. § 1.401(a)(9)-6(m)(4)(i)(B) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    …al 2028 $1,000,000 $550,000 2029 1 954,545 2 $561,000 3 $555,500 4 $26,606 534,934 2030 909,306 545,633 540,283 26,482 519,151 2031 864,291 529,534 524,342 26,760 502,774 2032 819,740 512,829 507,801 27,177 485,652 2033 775,430 495,365 490,509 27,438 467,927 2034 731,620 477,286 472,606 27,853 449,433 1 $1,000,000 deat…