IRCCourt RulingsMar 5, 2018★ strong match
¹² The Commissioner here also doesn't seek to redetermine income tax, but
only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a
distinction from Hellweg to let these cases go forward on the excise-tax issue
alone. Mazzei v…
IRCCourt RulingsJan 29, 2019
…tional tax imposed by
section 72(t) on the IRA distribution for 2010;
(3) whether the payment of $2,968 that petitioner received was taxable gross
receipts he should have reported on Schedule C, Profit or Loss From Business, for
2010;
¹(...continued)
to the nearest dollar.
- 3 -
(4) whether petitioner is entitled to de…
IRCCourt RulingsJan 14, 2013★ strong match
…1 7,572 18,764 (11,192)
1985 31,048 13,000 18,048 7,264 12,923 (5,659)
1984 29,955 6,000 ! 23,955 6,968 -0- 6,968
-26-
[*26]
1983 28,899 -0- 28,899 6,684 -0- 6,684
1982 27,881 -0- 27,881 6,412 -0- 6,412
1981 26,899 -0- 26,899 6,151 -0- 6,151
1980 25,952 -0- 25,952 5,900 -0- 5,900
1979 25,037 -0- 25,037 5,660 -0- 5,660
…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsFeb 18, 1998★ strong match
…Judge
: Respondent determined a deficiency in
petitioner's Federal income tax in the amount of $170,968 and an
accuracy-related penalty under section 6662(a)
1
in the amount of
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968★ strong match
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 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 11, 2024
… Tuma’s
2016 Form RRB – 1099–R reported a correspondingly smaller
contributory amount paid of $25 , 968 . And as to his supplemental
[* 3 ]
4
[* 4 ] annuity benefit , Mr. Tuma’s 2016 Form RRB– 1099 – R reported the
same $516 amount , for a total reported amount paid of $26 , 484 . Mr.
Tuma’s 2016 Form RRB– 1099 – R als…
IRCFinal Rules (FR)Aug 26, 2022
dividual × 69% × 10%= 4,968 claims.
Back to Citation
87.
IDR Payment Determination Notification (section 716(c)(5)(A) of ERISA).
Back to Citation
88. The Departments use a composite wage rate because different professionals will review different types of claims and groups of individuals. The wage rate of a physician …
IRCPrivate Letter RulingsDec 20, 2013
…nvestment with
insurance protection. In Century W ood Preserving Co. v. Commissioner , 69 F.2d 967,
968 (3d Cir. 1934), the court determined that the policies of insurance involved in this
case have a double aspect. They provide the present protection of ordinary life
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999★ strong match
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 2, 2021
…ion of the FSP, which are not determ inative of
this case, see Peterson v. Com m issioner, 827 F.3d 968, 970-980 (11th Cir. 2016),
aff’g in part, dism issing in part T.C. Mem o. 2013-271.
- 4 -
[*4] After her retirem ent from Mary Kay, petitioner took up a num ber of non-
Mary Kay activities. First, through a wholly ow…
IRCCourt RulingsSep 29, 1992
…,320.85 37.500 3,320.85
1983 262,000 10,218.00 13.538.85 45,000 13.538.85
1984 370,000 14,430.00 27.968.85 52.500 27.968.86
1985 27,968.85 60,000 27,968.85
1986 27.968.85 67.500 27.968.85
1987 200,000 20,000.00 47.968.85 75,000 47.968.85
For the plan years 1986 and 1987, Stephan contributed $7,999 and $196,293 to the p…
IRCCourt RulingsJun 18, 1959
…ed its depletion allowance and net income as follows:
mo 1961
Gross receipts..-. $1,714,327.10 $290,968.18
Less cost of operations.. (1,172,692.70)
Gross profits. 641,634.40 290,968.18
Less amount retained by lessee under profit-sharing agreement.-. (289,774.44)
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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCRegulationsMay 18, 2016
… uses an integration level of $20,000, which is 118 percent of the 1989 covered compensation of $16,968 for an individual reaching social security retirement age in 1989. The plan may use that integration level without satisfying paragraph (d)(8) of this section, provided the adjustment to the 0.75-percent factor requi…
IRCCourt RulingsNov 1, 2005★ strong match
…s so ill he was
unable to file.”); Black v. Commissioner
, T.C. Memo. 2002-307,
affd. 94 Fed. Appx. 968 (3d Cir. 2004); Watts v. Commissioner
,
T.C. Memo. 1999-416 (“taxpayer’s selective inability to perform
his or her tax obligations, while performing * * * regular
business, does not excuse failure to file”).
Although…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.) IRCPrivate Letter RulingsJun 25, 1999
…19
1952); Rev. Rul. 60-31, Situation 4
. In Rev. Rul. 72-25, 1972-1 C.B. 127, and Rev. Rul. 68-99, 1968-1 C.B. 193, an employee does not receive income as a result of
the employer's purchase of an insurance contract to provide a source of funds for
deferred compensation because the insuranc e contract is the employer's…