IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsAug 8, 2019related by meaning
he foregoing principles in mind, we turn to section 72(t)(2)(F) and
begin with its title: "Distributions from certain plans for first home purchases." Although statutory titles and section headings do not define a statute's meaning
and are not generally relied on at the expense of the statutory text itself, such titles…
IRCCourt RulingsJul 30, 1985related by meaning
Eanes as petitioner.
In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsDec 19, 1989related by meaning
e Tax Reform Act of 1986, sec. 701(a) of Pub. L. 99-514, 100 Stat. 2320, but sec. 701(a) of the 1986 Act amended sec. 55(c)(1) of the Code to provide: (c) Regular Tax.— (1) In general. — For purposes of this section, the term “regular tax” means the regular tax liability for the taxable year (as defined in section 26(b…
IRCCourt RulingsFeb 18, 1997related by meaning
s from petitioner's IRA's in
the total amount of $181,481. Of this amount, petitioners
reported $8,762 as the taxable amount.
The Notice of Deficiency In the notice of deficiency, respondent determined that the
difference between the amount distributed from petitioner's IRA's
(i.e., $90,662.11 + $90,818.53 = $181,480.6…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
ble to a participant or beneficiary. M sec.
1.401(a)-13(c)(1), Income Tax Regs.
We clearly described the antialientation procedures under the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, 88 Stat.
- 14 -
[*14] 829, 29 U.S.C. sec. 1001 (2006), and the Internal Revenue Code in Gallade
v. Co…
IRCCourt RulingsApr 22, 1992related by meaning
tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows:
8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
atio = 1.47 × (1,400,000/10,509,091) = 0.196 = 19.6 percent.
Proposed Revocation of Parts I(b), I(c) and II(2) of PTE 75-1 and Restatement of PTE 75-1 The Department is proposing to revoke Parts I(b), I(c) and II(2) of PTE 75-1. In connection with the proposed revocation of Part II(2), the Department is republishing Pa…
IRCCourt RulingsJun 30, 2004related by meaning
nnuity described in section
408(b).” Sec. 7701(a)(37) (an individual retirement plan is
commonly referred to as an IRA). Section 72(t)(2)(E) was added by section 203(a) of the Taxpayer Relief Act of 1997, Pub. L.
105-34, 111 Stat. 788, 809. The Report of the Committee on the
Budget refers only to withdrawals from IRAs.…
IRCCourt RulingsDec 11, 2003related by meaning
oner
, supra
at 780.
11
See id.
at 773.
12
See Eckel v. Commissioner
, T.C. Memo. 1990-174.
13
See, e.g., In re Hatton
, 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang
, 164 F.3d 1029, 1033 (6th Cir. 1999).
section 6653(a),
3
section 6662,
4
section 6013,
5
section 6033,
6
section 6651(f),
7
section 6511,
8
sect…
IRCCourt RulingsJul 27, 2004related by meaning
7 (1989); Estate of Rosenberg v.
Commissioner
, 73 T.C. 1014, 1017-1018 (1980). Although we
acknowledge that petitioners used the IRA distribution for laudable purposes, absent some constitutional defect we are
constrained to apply the law as written, see Estate of Cowser v.
Commissioner
, 736 F.2d 1168, 1171-1174 (7th…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
tionary authority or control with respect to IRAs could continue to rely on PTE 86-128, as long as they comply with all of the exemption's conditions. The Department is also proposing certain technical changes to the exemption, including deleting subsection IV(b)(1), and redesignating remaining sections as needed. The …