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84 documents · 0.16sAllIRCERISAPBGCJoint Board
  1. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
    IRCCourt RulingsJun 24, 1966
    Exclusion — Ys of $5,000.00_ 1, 666. 67 Taxable Income_ 666. 66 The deficiency notice issued to Bertha makes the following adjustment to 1961 income: (a) Dividend Income_$1, 000. 00 Pro-rata distribution from John O. Nordt Company, Inc., designated as a pension paid to a deceased officer’s beneficiary, is includable i…
  2. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …not to Qulart, apparently because of an error. The total of the investor notes was therefore $2,888,666, an amount equal to tenelevenths of MIT 83's capital. On July 1, 1983, Qulart issued to Machise a 12-percent promissory note in the amount of $2,888,666, whose provisions tracked the provisions of the partners' notes…
  3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    …governing the assessment, collection, and payment of the section 6654 addition are found in section 6665. In pertinent part, section 6665(a) provides that (1) the section 6654 addition is to be paid upon notice and demand and is to be assessed, collected, and paid in the same manner as taxes, and (2) references in the …
  4. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012★ strong match
    …. 3. 042 Calculation of the Amount;of thé Penalty Although we sustain the imposition of the section 6662A penalties, we disagree with certain aspects of respondent's calculations. Generally, section 6662A applies, as relevant here, "to any item which.is attributable to" any listed transaction. Sec. 6662A(b)(2)(A). Resp…
  5. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000★ strong match
    … petitioner is liable for the addition to tax under section 6654 for the 1996 taxable year. Section 6662(a) provides for an accuracy-related penalty in the amount of 20 percent of the portion of an underpayment of tax attributable to, among other things, negligence or disregard of rules or regulations. Sec. 6662(a) and…
  6. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    …ner bears the burden of production with respect to an individual taxpayer's liability for a section 6662(a) or 6662A accuracy-related penalty. This burden requires that respondent produce sufficient evidence indicating that it is appropriate to impose either or both penalties in these cases. See sec. 7491(c); Higbee v.…
  7. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68 (3d Cir…
  8. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022
    …return he reported that petitioners had contributed to CRAT II c orn and soybeans with a n FMV of $ 666,975 and a cost basis of zero. 2 For purposes o f this litigation respondent has not challenged the validity of CRAT I or CRAT II. 4 [* 4 ] For each year the trustee filed for each CRAT a Form 5227, Split - Interest T…
  9. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …rk royalty had been calculated without using the stacking principle, the royalty would have been $4,666,187. If true, this means that 3M Brazil overpaid the trademark royalty to 3M Company by $438,569, which is the difference between $5,104,756 and $4,666,187. But petitioner does not assert that the income of the 3M co…
  10. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    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…
  11. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    … will be eliminated in the Rule 155 computation in accordance with respondent's concession. Section 6662 Penalty Respondent has the burden of producing evidence that the section 6662(a) penalty applies. See sec. 7491(c). Section 6662(a) and (b)(1) and (2) imposes a 20% accuracy-related penalty on any underpayment of Fe…
  12. T.C. Memo. 2009-38 — Nancy Garza-Martinez v. Commissioner
    IRCCourt RulingsMar 23, 2009
    …expectancy . See Rev . Rul . 2002-62, 2002-2 C .B . 710 ;, Notice 89-25, Q&A-12, 1989-1 C .B . 662, 666 . 7 - Section 72(t)(4)4 provides that the-exception found in section
  13. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017related by meaning
    or $5,000. Sec. 6662(d)(1)(A). The term "understatement" means the excess of the amount of tax required to be shown on the return for the taxable year over the amount of tax imposed that is shown on the return, reduced by any rebate. Sec. 6662(d)(2)(A). The Commissioner bears the burden of production with respect to th…
  14. T.C. Memo. 1998-52 — Robert E. Dunham v. Commissioner
    IRCCourt RulingsFeb 9, 1998related by meaning
    this case of most of the enumerated badges of fraud. Accordingly, petitioner is liable for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to make timely estimated income tax payments. Where prepayments of tax do not equal the percentage of total liabil…
  15. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    includes any careless, reckless, or intentional disregard. Sec. 6662(c). Negligence has also been defined as a lack of due care or failure to do what a reasonable person would do under the circumstances. Leuhsler v. Commissioner , 963 F.2d 907, 910 (6th Cir. 1992), affg. T.C. Memo. 1991-179; Antonides v. Commissioner …
  16. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    …f the death benefit attributable to the increase in Participant A's accrued benefit is therefore $6,666 ($56,333 − $49,667).(vii) Participant A's projected accrued benefit at normal retirement based on average compensation as of the end of 2010 is $8,840 [.01 × 17 years of service at age 65 × ($50,000 + $52,000 + $54,0…
  17. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tax status, it should also have jurisdiction over section 6652(c) (1) for purposes of section 6330(d)(1): This [Court] has jurisdiction to adjudicate whether a tax ehempt organization has unrelated business taxablþ income pursuant to IRC §512, as well as to determine any penalties in connection with such an assertion,…
  18. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    exceptions contained therein. See Recklitis v. Commissioner , 91 T.C. 874, 913 (1988); Tillman v. Commissioner , T.C. Memo. 1996-8. Because petitioner has not shown that any one of the exceptions applies, we sustain respondent's determination on this issue. IV. Section 6673--Penalty Awarded by Court We decide sua spont…
  19. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    …pany receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 percent on the portion of an underpayment attributable to negligence, disregard of rules or regulations, or a substantial under…
  20. T.C. Summary Opinion 2003-43 — Dennis W. Farley, Jr. & Janice J. Farley v. Commissioner
    IRCCourt RulingsApr 22, 2003
    …three permissible methods for calculating such a series. IRS Notice 89-25, Q&A-12, 1989-1 C.B. 662, 666. Petitioner chose the second of the three methods, known as the fixed amortization method. Rev. Rul. 2002-62, 2002-42 I.R.B. 710. The fixed amortization method involves amortizing a taxpayer’s IRA account balance ove…