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 …
IRCCourt RulingsJun 18, 1959
… 151.66 298.43
Taxes. 1,074.34 2,140.98
Contributions. 206.00
Depreciation. 73.61 515.70
Depletion. 119,689.38 131,494.22
Other deductions. 5,385.15 11,026.00
Total deductions. (133,370.64) (161,352.83)
Net income.-120,210.13 131,494.22
Depletion computation:
Total production (sales) 1,714,327.10 1,935,793.57
Share of …
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…s are Implementing the Rule Package,
Deloitte, (Mar. 6, 2020).
485.
The burden is estimated as: (3,119,833 rollovers x 48% × (30 minutes ÷ 60 minutes)) + (3,119,833 rollovers × 52% × (5 minutes ÷ 60 minutes)) = 883,953 hours. A labor rate of $219.23 is used for a personal financial adviser. The labor rate is applied i…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
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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…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsMay 23, 2011
…lth insurance and
pension plans but declined to do so. See Feaster v.
Commissioner, T.C. Memo. 2010-157 (the availability and not the
receipt of benefits is the determinative factor); see also Weber
v. Commissioner, 103 T.C. at 393-394; Colvin v. Commissioner,
T.C. Memo. 2007-157, affd. 285 Fed. Appx. 157 (5th Cir. 200…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsDec 18, 2012★ strong match
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…
IRCCourt RulingsJun 17, 1997
…989
1990
1991
Fund value at yearend $99,996 $138,653 $158,161 $167,047
Policy values 99,996 138,653 157,814 167,055
Surrender value Unstated Unstated 136,959 147,056
Addit. contr. available (11) 2 61,519 128,443
Date of report 03/11/91 03/11/91 07/10/91 01/20/93
1992
1992
1993
1993
1994
Fund value at yearend $177,095 $…
IRCCourt RulingsOct 23, 2006related by meaning
T .C . Summary Opinion 2006-17 0
UNITED STATES TAX COUR T
NADER GHAZITEHRANI AND FARZANEH ZAMANIZADEH, Petitioners v .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 12653-05S . Filed October 23, 2006 .
Nader Ghazitehrani and Farzaneh Zamanizadeh, pro sese .
Aimee R . Lobo-Berg , Thomas J . Travers , and Ann…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…mination letter
156
.05 Opinion letter
156
.06 Oral advice
156
.07 Nonbank trustee approval letters
157
.08 Compliance statement
157
.09 Advisory letter
157
SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE?
158
SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT…
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
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(3) If at any time the correction of the
error is authorized as to one such t…
84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…equirements for the disclosure of an NSFR are described in the NSFR proposed rule.
Back to Citation
119.
See 12 U.S.C. 3104.
Back to Citation
120.
See, e.g.,
Linda Goldberg and David Skeie, “Why Did U.S. Branches of Foreign Banks Borrow at the Discount Window during the Crisis,” Federal Reserve Bank of New York Lib…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsOct 10, 2018related by meaning
t was not a payment. The levy proceeds were an involuntary payment, and therefore
R did not abuse his discretion in applying the levy proceeds against Ps' 1995 income tax liability.
Hel_d, further, R's determination to deny Ps' installment
agreement proposal was not an abuse of discretion.
Juan F. Vasquez, Jr., and Ren…
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
…ding the transition rule for dividends (the “transition rule”) in section 70354(c)(2) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act. The transition rule modifies the application of section 951(a)(2)(B) of the Internal Revenue Code for certain taxable years of fore…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsFeb 24, 2016
… Afterwards, he transferred the funds between his accounts and eventually
¹²Ancira v. Commissioner, 119 T.C. at 136-137.
¹³Ancira v. Commissioner, 119 T.C. at 137-139.
¹4Ancira v. Commissioner, 119 T.C. at 137.
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[*16] to Mr. Carver. These actions show that he had unfettered control over the
funds. Accordingly, he…