IRCCourt RulingsJul 21, 2008
…. 3
On April 19, 2004, Fidelity sent Ms . Tilley a check for
$61,479 .94, which represented the $76,849 .93 balance of her plan
account less $15,369 .99 in Federal tax withholding . Petitioner s
2 Although Fidelity Investments sent the letter to Ms .
Tilley, Fidelity Management Trust Co . is listed as the plan's
admini…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
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 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…
IRCCourt RulingsOct 9, 1997
…account
limit ($8,447,418) equals the amount of the actual contribution
which is not allowable ($29,849,690) as a current deduction.
Because the disallowed amount ($29,849,690) is greater than the
Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u… IRCNoticesApr 6, 2009
$275,386 $262,282 $268,849 $267,848
* Entries reflect the sum of the amounts for the current and later quarters, as illustrated for expected earnings. Average of adjusted fair market value of assets at earlier determination dates and fair market value at valuation date:($275,386 + $262,282 + $268,849 + $267,848 + $274,…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ansaction does not qualify for a deduction under section 170. Graham
v. Commissioner, 822 F.2d 844, 849 (9th Cir. 1987), aff’g 83 T.C. 575
(1984), aff’d sub nom. Hernandez v. Commissioner, 490 U.S. 680; see also
Costello v. Commissioner, T.C. Memo. 2015-87, at *27. By contrast , if
IRCCourt RulingsJun 24, 2003related by meaning
substantiation requirements of
section 1.213-1(h), Income Tax Regs. Petitioners claimed a
medical expenses deduction of $9,847. Petitioners provided a computer printout detailing the expenses but failed to provide
any underlying evidence or documentation to substantiate the
claimed deductions. During trial Mr. Palomo w…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…liam Shaw V.P. Sales & $85,000 $196,889 $281,889
Marketing
Jim Dinwoodie St. Acct. Exec. 30,000 184,849 214,849
(Dallas)
Jim Discher Sr. Acct. Exec. 25,000 213,426 238,426
(Detroit)
William Shumate V.P. Travel 110,000 92,500 202,500
Earl Nelson V.P. Travel 110,000 92,500 202,500
FY-89
William Shaw V.P. Sales & 85,000 6…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsOct 25, 1999related by meaning
spondent's determination
that she is liable for a 10-percent additional tax on her 1995
IRA distribution. Since petitioner fails to qualify for any of the statutory exceptions under section 72(t)(2), we hold that
petitioner is liable for the 10-percent additional tax on
distributions from a qualified retirement plan fo…
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
.
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 …
IRCProposed Rules (FR)Proposed May 13, 2026
…y wage rate for attorney × 811 issuers = $152,127.
Back to Citation
172.
This is estimated as: (42,849,310 potentially eligible private-sector individuals × 42 percent notice mailing rate) + (11,561,954 potentially eligible public-sector individuals × 66 percent notice mailing rate) = 25,499,052 notices mailed.
173.
…
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…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…Departments estimate a total one-time burden of 303,360 hours and a total cost of approximately $42,849,600.
The Departments request comment on the estimated cost and burden hours presented in this analysis, including any additional costs or challenges that commenters may identify.
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…