IRCCourt RulingsFeb 18, 1997★ strong match
…Loan
distributed, and petitioner received, the account balance of
- 7 -
petitioner's IRA; i.e., $90,662.11, which consisted of
petitioner's initial deposit and earnings as follows:
IRA deposit: $ 82,900.00
Earnings: 7,762.11
Total distribution: 90,662.11
Distribution of the Delaware Charter IRA
In a letter to Delaware …
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 …
IRCProposed Rules (FR)Proposed Dec 23, 2025
…file per month (3,600 downloads each year). At this rate, the total annual cost is estimated at $67,662,000 ($18,795 × 3,600).
Back to Citation
216.
Estimated annual size data transfer cost savings are calculated by subtracting the total annual cost for the optimized 300TB files ($67,662,000) from the total annual cos…
IRCCourt RulingsDec 18, 2012★ strong match
…Respondent determined that she realized unreported income of
$11,122, $22,520, $8,502, $50,003, $11,662, and $2,840 during the subject years.
Respondent further determined in Ms. Zaklama's notice of deficiency that
she received premature withdrawals from her retirement accounts. Respondent
determined that the withdrawa…
IRCCourt RulingsJan 17, 2024related by meaning
…ned additions to tax under section
6651(a)(1) and (2) and accuracy-related penalties under section 6662(a) .
Respondent has since conceded th e section 6651(a)( 2 ) additions to tax
and the penalties .
Currently before the Court is respondent’s Motion for Partial
Summary Judgment . H e seeks a ruling that section 4973 …
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 RulingsApr 22, 2003★ strong match
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
IRCCourt RulingsOct 17, 1995
…09 -0Telephone 587.75 -0- 1,342.33 (1,342.33)
Miscellaneous -0- 8,331.42 -0- 8,331.42
Meals -0- -0- 662.73 (662.73)
Depreciation 2,248.00
2,889.00
2,889.00
-0-
Total 20,603.76
37,494.61
28,331.15
9,163.46
Section 62(a)(4) allows the deduction of expenses
IRCCourt RulingsMar 16, 2015related by meaning
…n includible in gross income; and that he was liable for an
accuracy-related penalty under section 6662(a). The IRS timely mailed petitioner
a notice of deficiency setting forth these determinations, and petitioner timely
sought review in this Court. On November 19, 2014, respondent filed a motion
for summary judgment,…
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 RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
IRCCourt RulingsMay 23, 2005
…ackaging stopped deducting loan
payments from Mr. White’s paychecks, the unpaid loan balance was
$6,662. No further loan payments were ever made. After
expiration of the “cure” period in 2001, the loan was treated by
the plan administrator as having been defaulted.
Fidelity Investments issued a Form 1099-R, Distributio…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…ties, LLC (DESE Properties), a disregarded entity of DESE Research, Inc. (DESE
Research), purchased 662.42 acres of land in Madison County, Alabama
(Parent Parcel) , for $1,059,872, or $1,600 per acre. DESE Properties
referred to the 662.42 acres of land that make up the Parent Parcel as
the “Meeks Mountain property.” …
IRCCourt RulingsAug 30, 1999
…premature withdrawal fee which BayBank charged
Mr. Czepiel and that those distributions totaled $30,662. See
Cal-Maine Foods, Inc. v. Commissioner
, 93 T.C. 181, 195 (1989).
the $8,000 that he withdrew from IRA 2 to Ms. Czepiel's attorney.
Consequently, on July 31, 1995, the Family Court ordered petitioner's release fr…
IRCPrivate Letter RulingsMar 6, 2015
…h from IRA X calculated
using the fixed annuitization method described in Notice 89-25, 1989-1 C.B. 662
("Notice 89-25"). IRA X included both a bank account and a securities account. The
fixed payments were made from the bank account.
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…
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…
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…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…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 trust during
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-…