IRCCourt RulingsSep 24, 2007
…41 deficiency for petitioner's 2002 taxable
year . The issues for decision are :
(1) Whether a $168,355 pension distribution to petitioner in
2002 pursuant to a qualified domestic relations order (QDRO) is
includable in petitioner's 2002 taxable income ;
(2) whether $8,119 .20 of the $9,552 in Social Security
benefits …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…engages in commercial activity with respect to the real property interest transferred. (28) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
IRCCourt RulingsFeb 6, 2024
…ioner ,
50 T.C. 585, 592 (1968 ) ) ; accord Benes v. Commissioner, 42 T.C. 358, 381
(1964), aff’d , 355 F.2d 929 (6th Cir. 1966) ; see also Corliss, 281 U.S.
at 378; Treas. Reg. § 1.451-2(a). As discussed below, t his Court has
consistently applied the constructive receipt doctrine in cases where the
taxpayer’s assets …
IRCRegulationsJan 19, 2017
…plicable with respect to stock acquired by a distribution or an exchange to which section 305, 354, 355, 356, or 1036 (or so much of section 1031 as relates to section 1036) applies. Stock so acquired shall, for purposes of sections 421 through 424, be considered as having been transferred to the individual upon his ex…
IRCProposed Rules (FR)Proposed Dec 23, 2025
s in an annual storage savings of roughly $57,355,200 [210]
for the 300 third-party developers and other files users based on file-size optimizations. However, because these proposed rules also shift the reporting frequency from monthly to quarterly, total storage needs and corresponding savings would be reduced accord…
IRCCourt RulingsFeb 9, 2023★ strong match
ory change was
discussed in the “Introduction” portion of the preamble to Treasury
Decision 8470. 58 Fed. Reg. 5264. Treasury Decision 8470 was issued the same day as the notice of proposed rulemaking , January 21, 1993,
setting forth the proposed regulations on foreign legal restrictions. T.D.
8470, 58 Fed. Reg. 5310;…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsJan 3, 2011
…of thee$36,000 was credited towards the
cash value of petitioner' s life insurance policy. The $17, 355
excess contribution was not credited toward the cash value of the
life insurance policy covering petitioner discussed in the PERC
valuation above . Consequently, the inclusion of the excess
contribution in petitioner…
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 18, 2012
0- (1,561) -0-
(3,763) (2,116) -0-
-0- (1.461) -016,087 15,355 19,542
Respondent determined that each petitioner realized one-half of the total rental income for 1995, 1996, and 1997. These amounts are as follows:
1995 1996 1997
Deposited rent $17,908 $41,810 $2,730
Additional rent 16,087 15,355 19,542
Total rent 33,99…
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 RulingsJul 31, 2000
…of that year, the conversion credit balance was $124,364.78 ($77,954.39 + $53,150 - $12,095.03 + $5,355.42); the
$5,355.42 is the interest of 4.5 percent earned on the conversion
credit balance (($124,364.78 - $5,355.42) x 4.5% = $5,355.42)).
Of the conversion credit balance, $112,239.22 could have been
transferred at …
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
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…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
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. …
IRCRegulationsJul 12, 2016
… 15% of $100,000=) 115,000 120,000 1982 500,000 (20% of $500,000=) 100,000 100,000 Totals 1,800,000 355,000 420,000 (2) Organization X, whose taxable year is the calendar year, was organized in 1971. X first made the expenditure test election under section 501(h) effective for taxable years beginning with 1979 and has …
IRCCourt RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
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…