IRCCourt RulingsDec 18, 2012
…her petitioners' gross income for the subject years includes rental
income of $21,113, $11,460, $13,428, $33,994, $57,166, and $22,272,
respectively. We hold that it does. We also decide whether petitioners may deduct
IRCCourt RulingsJul 14, 2005★ strong match
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 RulingsOct 3, 1989★ strong match
…Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986.
H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. 2d Sess. at 169 (1962), 1962-3 C.B. 707, 731. Cf. Sanford v. Commissioner, 50 T.C. 823, 826 (1968), affd. per curiam 412 F. 2d 201 …
IRCCourt RulingsApr 12, 2000
…ule C, Profit
and Loss From Business, of his 1995 tax return, petitioner reported deductions of $70,428.52 from his automobile drag racing
activity named Emerson Racing Enterprises. Petitioner reported
no income from this activity, resulting in a $70,428.52 loss.
Related to this loss in 1995, petitioner carried back a …
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 RulingsSep 10, 2015
…ng the magistrate
judge's findihgs and recommendation.
On December 7, 2009, FHB issued a check for $428,103.63 from
petitioner's IRA to the clerk of the District Court. Additionally, on December 8,
2009, FHB i sued a check for $89,343.98 from petitioner's IRA to UPW.
Thereafter, FHB issued a Form 1099-R, Distributions …
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…Apart
33,000
33,000
550.00
16,280
Sub-Total
17,384,942
8,708,971
145,150
4,296,426
Uniform Glossary
428,232
428,232
7,137
211,261
Notice of Modification
342,585
171,293
2,855
84,504
Individual Market:
SBC with Coverage Examples
21,784,217
6,535,265
108,921
3,224,064
Uniform Glossary
762,448
762,448
12,707
376,141
Notic…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
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1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
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 RulingsJan 9, 1985related by meaning
erest) on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960
…owed the deduction.
On January 1, 1951, petitioner bad a reserve for bad debts in the amount of $2G,428.41. During the years 1949 to 1958, inclusive, petitioner had the following bad debts which were charged against the reserve in each of the years as follows:
Bad debts charged' Year against reserve
1949 _$2,160.91
195…
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 RulingsApr 22, 2003related by meaning
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.
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The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…nd d id not provide any
recommendation or other advocacy to LA County. Cf. Stubbs v. United
States, 428 F.2d 885, 887 – 88 (9th Cir. 1970) ( determining that the quid
was assistance in obtaining favorable zoning provided by the donee);
Hernandez v. Commissioner, 819 F.2d 1212, 1217 (1st Cir. 1987)
( determining that th…
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…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…86 (2015); and then citing Green v.
Commissioner, 707 F.2d 404, 405 (9th Cir. 1983) , rev’g 78 T.C. 428
(1982) ) . “ [W]hen deciding whether the language is plain, we must read
the words ‘ in their context and with a view to their place in the overall
statutory scheme. ’” King , 576 U.S. at 486 (quoting FDA v. Brown &
…
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 RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…uld incur a total one-time burden of 10,112 hours with an associated total cost of approximately $1,428,320. Under the high-end scenario, for all issuers and TPAs, the total one-time burden would be 50,560 hours with an associated total cost of approximately $7,141,600, as shown in Table 16.
( printed page 60476)
IRCPrivate Letter RulingsAug 20, 2004
…d 541 (6th Cir. 1952); Rev. Rul. 60-31,
Situation 4
. Section 3.01 of Rev. Proc. 92-65, 1992-2 C.B. 428, states that in each request
for a ruling involving the deferral of compensation, the Internal Revenue Service
(“Service”) will determine whether the doctrine of constructive receipt is applicable on a
case by case b…