89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
… 1.985-4 also issued under 26 U.S.C. 985.
Section 1.985-5 also issued under 26 U.S.C. 985, 987, and 989.
* * * * *
Section 1.987-1 also issued under 26 U.S.C. 987, 989, and 1502.
Section 1.987-2 also issued under 26 U.S.C. 987, 989, and 1502.
Section 1.987-3 also issued under 26 U.S.C. 987 and 989.
Section 1.987-4 also…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
U.S.C. 987 and 989(c).
Section 1.987-8 also issued under 26 U.S.C. 987 and 989(c).
Section 1.987-9 also issued under 26 U.S.C. 987, 989(c), and 6001. Section 1.987-10 also issued under 26 U.S.C. 987, 989(c), and 6001.
Section 1.987-11 also issued under 26 U.S.C. 987, 989(c), and 1502.
Section 1.987-12 also issued unde…
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 RulingsJan 16, 2002★ strong match
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
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…
IRCRegulationsSep 9, 2016
…the effective interest rate for Plan F for the 2016 plan year, plus 5% ($8,000 ÷ 1.1090(5/365) = $7,989). The result is further adjusted for the 105 days from the due date for the required installment to the valuation date of January 1, 2016 using the effective interest rate of 5.90% ($7,989 ÷ 1.0590(105/365) = $7,858)…
IRCCourt RulingsOct 3, 1995related by meaning
…e, fall within the scope of this Court's jurisdiction.
Perkins v. Commissioner
, 92 T.C. 749, 752 (1989); LTV Corp. v.
Commissioner
, 64 T.C. 589, 597 (1975); see sec. 6404(e); Marine
v. Commissioner
, 92 T.C. 958, 994 (1989), affd. without published
opinion 921 F.2d 280 (9th Cir. 1991); 508 Clinton St. Corp. v.
Commis…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
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 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 RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
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 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 RulingsJun 16, 1987related by meaning
GOFFE, Judge:
The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
IRCCourt RulingsMay 27, 2010
…rcio (Docket No . 1768-07)
Accuracy-Related Penalty
Year Deficiency Sec . 6662(a )
2001 $79,946 $15,989
2002 81,568 16,314
2003 72,098 14,420
2004 63,519 12,70 4
Ronald D . Jelling and Lorie A . Jelling (Docket No . 1769-07 )
Accuracy-Related Penalty
Year Deficiency Sec . 6662(a )
2001 $79,946 $15,989
2002 81,568 16,31…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsMar 24, 1980
…17 987,196
Bonus 44,879.48 73,770.15 85,760.68 123,272
Total 493,674.40 815,071.65 943,367.46 1,355,989 990,796
Profit-sharing 72,689.89 120,383.34 139,472,13 200,766 146,227
Total 566,364.29 935,454.99 1,082,839.59 1,556,755 1,137,023
Donald J. Carter
Salary $2,400.00 $2,400.00 $2,400.00 $2,400 $2,400
Commission 359,6…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…