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81 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tinued...) - 5 - of the Secretary, and in the same manner as taxes. Sec. 6652(c) (4) (A). Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect the tax by levy upon the property belonging to the person, subject to …
  2. 124 T.C. No. 10 — John Michael Dunkin v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    RO was not required here, we see no “clear and unequivocal” congressional intent for Federal law to supplant State law, see Mansell v. Mansell , supra , and no reason to avoid taxation of petitioner according to his rights and obligations under California community property law. E. Conclusion We conclude that petitione…
  3. T.C. Memo. 1996-240 — Richard L. & Betty L. Seltzer v. Commissioner
    IRCCourt RulingsMay 23, 1996
    …90 1991 PERS $3,649.32 $3,748.32 $3,847.32 U.S. Army 13,939.68 14,736.99 15,581.40 OPM 11,447.84 13,680.00 14,412.00 Total $29,036.84 $32,165.31 $33,840.72 During the year 1989, after having his annuity distributions reduced as discussed above, petitioner received annuity benefits from OPM in the amount of $11,447.84. …
  4. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…
  5. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021
    …luation for the AE silver coins. It valued the 2015 AE gold coins as of Decem ber 31, 2015, at $347,680 and valued the 2015 and 2016 AE gold coins as of Decem ber 31, 2016, at $381,022. Kingdom Trust required Mrs. McNulty to provide a yearend valuation of her IRA’s assets. She com pleted a valuation form that she subm …
  6. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  7. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  8. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    … "Management Fee" . The amounts were as follows:" Date Amount Sept. 30, 2002 $600,000 Oct. 31, 2002 680,000 Nov. 30, 2002 995,000 Dec. 31, 2002 700,000 Total 2,975,000 Weekend Warrior paid Leading Edge as follows: Date Amount Dec. 20, 2002 $600,000 Dec. 27, 2002 700,000 Dec. 30, 2002 680,000 Dec. 31, 2002 995,000 Total…
  9. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  10. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …,887,918. In the notice of deficiency, respondent did not make a separate negative adjustment of $8,680,625 to reverse petitioner’s reported Schedule E passthrough income from Morley of $8,680,625. Rather, respondent adjusted Mr. Larson’s pro rata 9 [* 9 ] determined that all or part s of Mr. Larson’s underpayments of …
  11. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006related by meaning
    hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan. ADMINISTRATIVE Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
  12. 76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary
    IRCProposed Rules (FR)Proposed Aug 22, 2011
    …timate a one-time administrative cost of about $36,000,000 across the industry and a total of about 680,000 burden hours to prepare for the provisions of these proposed regulations. This calculation is made assuming issuers and TPAs will need to implement two principal tasks: (1) Develop teams to analyze current workfl…
  13. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  14. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  15. Treas. Reg. § 1.72-5(a)(2)(i) — Expected return.
    IRCRegulationsJul 26, 2016
    …cing 12 full months after his annuity starting date, the amount of the expected return would be $16,680 ($1,200 × 13.9 [14.4−0.5]).
  16. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    ents was this estimate, to which respondent reserved an objection on grounds of relevance and authenticity. We overrule respondent's objection. - 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets to the extent of the gain from such sales or exchanges, plus the lower of: (1) $3,000 o…
  17. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971related by meaning
    n will be entered under Rule 50. Drennen, /., dissents. All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
  18. 87 FR 60357 — User Fees Relating to Enrolled Actuaries
    IRCProposed Rules (FR)Proposed Oct 5, 2022
    …me of applications expected over the same three-year period to determine a per-application cost of $680.00, as shown below: Total Costs $2,674,248 Number of Applications ÷   3,930 Cost per Application $680 Special Analyses I. Regulatory Planning and Review
  19. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
  20. 88 FR 72366 — User Fees Relating to Enrolled Actuaries
    IRCFinal Rules (FR)Oct 20, 2023
    …initially enrolling as an enrolled actuary with the Joint Board for the Enrollment of Actuaries is $680.00. * * * * * (d) Applicability date. This section is applicable beginning November 20, 2023. Par. 3. Section 300.8 is amended by revising paragraphs (b) and (d) to read as follows: § 300.8 Renewal of enrollment of e…