IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
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…
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 RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
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…
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
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976★ strong match
… 928 n. 4 (1949) (dicta). See also D. E. Brown, 1 B.T.A. 446 (1925); Mead Cycle Co., 10 B.T.A. 887, 896-897 (1928); Owens, The Foreign Tax Credit, sec. 7/3C (1961). Ravenscroft, Taxation and Foreign Currency, sec. 14/3.2C (1973).
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. …
IRCCourt RulingsMay 1, 1996related by meaning
n annuity payment.
Discussion
Respondent determined that, based on the exclusion ratio
calculated pursuant to section 72(b), petitioners were required to include a portion of the lump-sum payment from petitioner’s
CSRS in their gross income in 1987. Petitioners argue that such
inclusion would result in double taxation …
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 …
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…
IRCCourt RulingsMar 11, 2020★ strong match
…
case.
Respondent determined that petitioners are liable for a Federal income tax
deficiency of $28,896 for the taxable year 2013 (year in issue), an addition to tax
for late filing under section 6651(a)(1) of $6,595, and an accuracy-related penalty
under section 6662(a) of $5,779. Petitioners, husband and wife, filed …
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…
IRCCourt RulingsMar 10, 2020★ strong match
…r Courts of Appeals follow the same framework. See, e.g., Young v.
United States, 332 F.3d 893, 895-896 (6th Cir. 2003); Edwards v. Valdez, 789
F.2d 1477, 1482-1483 (10th Cir. 1986); Grauvogel v. Commissioner, 768 F.2d
1087, 1089 (9th Cir. 1985); Richards v. Commissioner, 745 F.2d 524, 525-526
(8th Cir. 1984), affg T.C…
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…
IRCCourt RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
IRCCourt RulingsJan 16, 2020related by meaning
is to be
-6included in gross income in the year in which the payment is received
rather than in the years to which the payment is attributable, to the extent that application of the formula results in a taxable amount.
The election merely provides an alternative method of applying the
formula to determine the taxable p…
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.
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 RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…