IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJul 21, 2008
…er , 108 T .C . 100, 102-103 (1997) ; F .W .
Woolworth Co . v . Commissioner , 54 T .C : 1233, 1265-1266 (1970) .
IRCCourt RulingsApr 2, 2020
…onal" means "in addition to" something else. See Air Transp.
Ass'n of Am. v. Lenkin, 899 F.2d 1265, 1266 (D.C. Cir. 1990). Applying this
IRCCourt RulingsSep 13, 2017
…is engaged benefited or was intended to be benefited by the expense.
Hynes v. Commissioner, 74 T.C. 1266, 1289 (1980); Chapman v. Commissioner,
48 T.C. 358 (1967). Section 1.162-5(a), Income Tax Regs., provides that a
taxpayer may deduct educational expenses as ordinary and necessary business
expenses if the education …
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
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 RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …
IRCCourt RulingsNov 10, 2004
…ommissioner
, 108 T.C. 100, 102-103 (1997);
F.W. Woolworth Co. v. Commissioner
, 54 T.C. 1233, 1265-1266
(1970).
Nevertheless, we find that respondent’s position in the
proposed regulation makes more sense than respondent’s litigating
position that the distribution occurred in 2000. See Garcia v.
Commissioner
, T.C. Me…
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 RulingsJun 3, 1998
… v. Commissioner
, 89 T.C. 357, 369
(1987); F.W. Woolworth Co. v. Commissioner
, 54 T.C. 1233,
1265-1266 (1970). Nonetheless, we find that respondent's
position in the proposed regulation makes more sense than
the respondent's litigating position in this case.
Respondent's litigating position is logically inconsistent
…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCCourt RulingsJul 9, 1997
…a position advanced by respondent on brief. F.W.
Woolworth Co. v. Commissioner
, 54 T.C. 1233, 1265-1266 (1970).
Our use of the word "offset" does not indicate any reliance on
the proposed regulation.
During tax year 1992, the Bank of New Hampshire foreclosed
on the timeshares. Petitioners received $15,000 in proceeds …
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
Notice 2014-27 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in April 2014; the 24-month average segment rates; … IRCNoticesApr 28, 2014
…766, Notice 2007–25, 2007–1 C.B. 760, Notice 2007–77, 2007–2 C.B. 735, Notice 2008–107, 2008–2 C.B. 1266, Notice 2010–27, 2010–1 C.B. 531, Notice 2011–8, 2011–1 C.B. 503, Notice 2012–19, 2012–1 C.B. 440, and Notice 2013–31, 2013–1 C.B. 1099.
EMPLOYEE PLANS
Notice 2014–27 Notice 2014–27
IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
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 RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
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 …