71 T.C. 874 — Shelby U.S. Distributors, Inc. v. Commissioner IRCCourt RulingsFeb 20, 1979
Simpson, Judge:
The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes: .
Taxable year Petitioner ending Deficiency
Shelby U.S. Distributors, Inc. 12/31/71 $31,908.28
12/31/72 43,626.74
Shelby Supply Co., Profit-Sharing Trust and/or U.S. Distributors Co. Div. Profit-Sharing Trus…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ployees 26,311,902
36,694,928
47,731,960
48,947,859
Total 39,673,488 75,216,785 110,592,106 132,541,874
2. Actuarial value of assets
VEBA -0- 30,736,554 30,176,217 39,940,676
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 RulingsJan 12, 1998related by meaning
ime of his distribution, we hold that
he is not liable for the sec. 72(t) additional tax.
In the notice of deficiency, there was no determination that petitioners Robert C. and Mary D. Borman were liable for the sec.
72(t) additional tax, but on brief, respondent made such an
assertion. See sec. 6214(c).
10-percent add…
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018
…vertising, $11,834 for car and
truck expenses, $2,003 for depreciation and section 179 expenses, $1,874 for legal
and professional services, $2,016 for office expenses, $890 for supplies, and
$7,356 for utilities.
On the Schedule A petitioners reported, among other items, $23,931 of
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 RulingsAug 27, 2026
…nceal, mislead, or otherwise
prevent the collection of ta xes.” DiLeo v. Commissioner, 96 T.C. 858, 874
(1991), aff’d , 959 F.2d 16 (2d Cir. 1992); see also Langille v.
Commissioner, 447 F. App’x 130, 134 (11th Cir. 2011), aff’g T.C. Memo.
2010- 49.
To sustain his burden, the Commissioner need not prove the
precise amo…
IRCCourt RulingsJul 31, 2000
…r
the third year was $1,798.22, and, at the end of that year, the
conversion credit balance was $19,874.34 ($12,844.23 + $7,972.50
- 39 -
- $1,798.22 + $855.83); the $855.86 is the interest of 4.5
percent earned on the conversion credit balance (($19,874.34 -
$855.83) x 4.5% = $855.83)). Of the conversion credit balanc…
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…
75 FR 51623 — Registration of Mortgage Loan Originators IRCFinal Rules (FR)Aug 23, 2010
…ecial Counsel, or Patrick T. Tierney, Senior Attorney, Legislative and Regulatory Activities, (202) 874-5090, and Nan Goulet, Senior Advisor, Large Bank Supervision, (202) 874-5224, Office of the Comptroller of the Currency, 250 E Street SW., Washington, DC 20219.
Board:
Anne Zorc, Counsel, Legal Division, (202) 452-38…
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 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…
75 FR 44656 — Registration of Mortgage Loan Originators IRCFinal Rules (FR)Jul 28, 2010
…ecial Counsel, or Patrick T. Tierney, Senior Attorney, Legislative and Regulatory Activities, (202) 874-5090, and Nan Goulet, Senior Advisor, Large Bank Supervision, (202) 874-5224, Office of the Comptroller of the Currency, 250 E Street SW., Washington, DC 20219.
Board:
Anne Zorc, Counsel, Legal Division, (202) 452-38…
89 FR 64538 — Quality Control Standards for Automated Valuation Models IRCFinal Rules (FR)Aug 7, 2024
…mate for AVM usage of 178 credit unions implies the aggregate compliance burden should not exceed 5,874 hours. To put this figure in context, the 1,789 credit unions under $100 million with residential mortgages on their books paid their employees an average of $33.13 per hour in salary and benefits.[109]
The upper-bou…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsSep 30, 1991related by meaning
023.94
81,023.94
81,023.94
81,023.94
64,819.15
For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…
IRCRegulationsJul 26, 2016
…lly determined with respect to pre-July 1986 investment in the contract 794.70 Pre-July 1986 amount 874.51 Post-June 1986 investment in the contract allocable to taxable years 1991 and 1992 ($640.39 × 2) $1,280.78 Less: Portion of total payments allocable to post-June 1986 investment in the contract actually received a…
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
Notice 2025-60 — This notice sets forth the 2025 Required Amendments List (2025 RA List). The 2025 RA List applies to individually designed plans qualified under section 401(a)… IRCNoticesDec 22, 2025
…idance on the effective date and application of section 960(d)(4) of the Code.
Notice 2025-78, page 874.
This notice describes proposed regulations that Treasury and the IRS intend to issue under section 70322 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act, providi…
IRCCourt RulingsSep 10, 2015related by meaning
n fund. Accordingly, because petitioner constructively received the
IRA distribuitions in 2009, they are includable in his gross income for that year. Petitioner lastly argues that the 2008 garnishment order violated the
Consumer C edit Protection Act as well as the Mandatory Victims Restitution Act.
Petitioner request…