IRCCourt RulingsMay 5, 2008
…(b) or (c), a spouse may seek equitable relief under section
6015(f) . Fernandez v . Commissioner , 114 T .C . 324, 329-331
(2000) ; Butler v . Commissioner , 114 T .C . 276, 287-292 (2000) .
The Internal Revenue Service (IRS) may relieve an individual
from joint and several liability under section 6015(f) if, taking
i…
IRCCourt RulingsApr 26, 2012related by meaning
ed in section 274(d). Sanford v. Commissioner, 50 T.C. 823, 827 (1968),
aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); Rodriguez v. Commissioner, T.C. Memo. 2009-22 (the strict substantiation requirements of section 274(d) preclude
the Court and taxpayers from approximating certain expenses).
r
- 12 -
Petitioners' tabl…
IRCCourt RulingsNov 25, 2008
…ly liable for the tax reported or
reportable thereon . Sec . 6013(d)(3) ; Butler v . Commissioner ,
114 T .C . 276, 282 (2000) . In certain circumstances a spouse may
obtain relief under section 6015 from such liability . One type
of relief under section 6015 is provided in section 6015(f) as
equitable relief "for any …
IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…0
0938-NEW
326
326
24
7,819
100
783,362
0
783,362
45 CFR 149.460
0938-NEW
75
75
146.67
11,000
101
1,114,612
0
1,114,612
Total
59,914
5,609,057
359,691
19,276,093
1,189,514
20,465,607
H. Submission of PRA-Related Comments
HHS has submitted a copy of these proposed rules to OMB for its review of the rule's information co…
81 FR 4599 — Applicability of Normal Retirement Age Regulations to Governmental Pension Plans IRCProposed Rules (FR)Proposed Jan 27, 2016
…10)(B) was amended by section 2(a) of Defending Public Safety Employees' Retirement Act, Public Law 114-26 (129 Stat. 319) (2015)) and section 308 of Protecting Americans From Tax Hikes Act of 2015 (PATH Act), enacted as part of the Consolidated Appropriations Act, 2016, Public Law 114-113 (129 Stat. 2422), to include …
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 …
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 RulingsJan 2, 2025
…e IRS and DOL
that he had engaged in a prohibited transaction with RSPT, which he
described as a $3,276,000 loan from RSPT to GVH to purchase the PCB
note . Around that same time, h e claim ed that RSPT executed a note
receivable in October 2010 for a $3.5 million loan to GVH and that he
had directed the $3,276,000 tra…
IRCCourt RulingsSep 19, 1978related by meaning
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
Docket No. TYE— Deficiency
10703-75 ..Oct. 31; 1970 $6,517.00
Oct.. 31, 1971 7,547.00
903-77 .Oct. 31, 1972 2,108.74
Sept. 30, 1973 2,067.29
The sole issue remaining for decision is whether petitioner is barred from …
89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Oct 28, 2024
…ing hour burden would be 50,160 hours, with an equivalent total annual cost of approximately $2,751,276 as shown in table 6. Table 6—Estimated Annual Cost and Hour Burden for All Issuers and TPAs To Train Customer Service Representatives To Provide Assistance to Consumers Related to New Contraceptive Statement in the I…
IRCCourt RulingsAug 22, 2002related by meaning
stribution should not
be subject to the 10-percent additional tax because she is
entitled to rely on the advice of respondent’s representatives.
- 7 - Although we cannot be certain whether petitioner
misunderstood the advice she received or whether erroneous advice
was rendered, that distinction does not make a differe…
IRCCourt RulingsJul 25, 2005related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
year in issue.
T.C. Summary Opinion 2005-103
UNITED STATES TAX COURT
BASMAN AHMAD AND KHITAM AMERNEH, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 266-04S. Filed July 25, 2005.
B…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsJun 23, 2015related by meaning
T.C. Summary Opinion 2015-37
UNITED STATES TAX COURT
CHARLES D. TRAINITO, Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7223-14S. Filed June 23, 2015.
Kevin Kilduff and Drew A. Morris, for petitioner.
R. Jeffrey Knight, Janet F. Appel, and Michael E. D'Anello, for respondent.
SUMMARY OPINION
NEG…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
Notice 2019-60 — Notice 2019-60 provides temporary relief with respect to the nondiscrimination requirements relating to benefits, rights, and features under closed defined ben… IRCNoticesDec 2, 2019
…t generally meet the eligibility conditions for the relief provided in Notice 2014-5, 2014-2 I.R.B. 276, as extended. Specifically, this notice provides that, if a plan satisfies the conditions specified in this notice, the plan is deemed to have satisfied certain of the nondiscrimination requirements relating to benef…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
Notice 2016-57 — Notice 2016–57 extends the temporary nondiscrimination relief for closed defined benefit plans that is provided in Notice 2014–5, 2014–2 I.R.B. 276, by making … IRCNoticesOct 3, 2016
…rimination relief for closed defined benefit plans that is provided in Notice 2014–5, 2014–2 I.R.B. 276, by making that relief available for plan years beginning before 2018 if the conditions of Notice 2014–5 are satisfied.
II. BACKGROUND
Notice 2014–5 provides temporary nondiscrimination relief for certain “closed” de…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.