IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2022
…yment of a user fee
234
.04 Exemptions from the user fee requirements
234
.05 User fees under EPCRS
235
.06 Requests involving multiple offices, fee categories, issues, transactions, or entities
235
.07 Method of payment
235
.08 Transmittal forms
236
.09 Effect of nonpayment or payment of incorrect amount
237
.10 Refun…
IRCCourt RulingsApr 30, 1997related by meaning
itioner can show
that he comes within one of the exceptions of section 6654(e).
Hudson v. Commissioner
, 103 T.C. 90, 110 (1994), affd. without
- 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears
the burden of proof on this issue, Baldwin v. Commissioner
, 84
T.C. 859, 871 (1985), and the record cont…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
IRCCourt RulingsSep 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsJun 12, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
T.C. Memo. 1996-272
UNITED STATES TAX COURT
TOMMY L. AND PATRICIA A. HOBSON, Petitioners v
. COMMISSIONER OF
INTERNAL R…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…to $22,587.
b. Section 702.236—Penalty for Failure To Report Termination of Payments Existing § 702.235 requires employers to notify the district director within 16 days after making a final payment of compensation. Existing § 702.236 provides that an employer who, on or after November 17, 1997, fails to notify the dis…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
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 …
85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAFinal Rules (FR)May 27, 2020
…/404(c) Disclosure
106
106
105
1,021
Annual QDIA Notice
16
16
16
156
Pension Benefits Statement
110
109
109
1,058
Subtotal: Gross Cost Savings [1]
419
419
416
4,046
Costs Imposed by the Final Rule:
Website
−27
−27
−26
−240
Initial Notification and Right to Opt Out
−138
−12
−12
−235
Notice of Internet Availability
−67
−…
IRCCourt RulingsDec 2, 2010related by meaning
aritable contributions
within the meaning of section 170; and
(5) whether petitioner is liable for an accuracy-related
penalty under. section 6662(a). Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended and in effect for
the year at issue, and all Rule references are …
IRCRegulationsJul 26, 2016
…2.8 2.7 2.5 107 4.0 3.8 3.6 3.4 3.2 3.1 2.9 2.7 2.6 2.4 108 3.9 3.7 3.5 3.3 3.1 3.0 2.8 2.7 2.5 2.3 109 3.8 3.6 3.4 3.3 3.1 2.9 2.7 2.6 2.4 2.3 110 3.8 3.6 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 …
IRCRegulationsMar 14, 2019
…10 9,000 $9,000 $91,000 6/326 × $1,674.85 91,000 C 75,000 175,000 250,000 500,000 1⁄2 15,000 15,000 235,000 6/326 × 4,325.15 235,000 Total 60,000 140,000 200,000 1,000,000 30,000 24,000 326,000 6,000.00 Column: (1) Member. (2) Earnings and profits of the taxable year. (3) Accumulated earnings and profits at beginning o…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCRegulationsSep 9, 2016
…f the limitation under section 401(a)(17) for years beginning in 2008, 2009, and 2010 is $230,000, $235,000, and $240,000, respectively, then the limitation under section 415(b)(1)(B) based on N's average compensation for the period of N's high three years of service is $235,000. Example 3.(i) Facts. The facts are the …
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…