IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
IRCCourt RulingsDec 18, 2012related by meaning
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 RulingsJul 31, 2000
…t of $22,916. At the time of conversion, the Cgroup term policy’s conversion credit balance was $13,143.16, and
$12,486 of that amount ($13,143.16 x 95%) was transferred to the
C-group conversion UL policy for potential earning. Dr. Desai
will earn this amount in 120 equal monthly installments,
beginning October 1996. …
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner IRCCourt RulingsAug 26, 2014
SA- t4dPd erns)
143 T.C. No. 5
UNITED STATES TAX COURT
PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24414-12. Filed August 26, 2014.
R disallowed Ps' deduction for contributions to their IRAs,
which Ps claim are deductible because the limitations on ded…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
IRCCourt RulingsFeb 24, 2011
…as let go
from his job, and he defaulted on the loan, at which time the
outstanding balance was $29,143.
Petitioner and her husband filed a joint Federal income tax
return for 2007. On the return, petitioner did not report the
defaulted loan of $29,143 from her husband's 401(k).
Petitioner attached to her joint return …
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 RulingsFeb 6, 1992related by meaning
fic terms and requirements that, in a reasonable manner, interpret and carry out the general concepts embodied in the statute and legislative history. Thus, we hold that the temporary regulation is valid.
Applicability of Temporary Regulation to Petitioner's Yearend Bonus Payments
In the alternative, petitioner argues …
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
January 15, 2020.
§ 726.302(c)(2)(i) table
$143
$146.
§ 726.302(c)(2)(i) table
285
290.
§ 726.302(c)(2)(i) table
428
436.
§ 726.302(c)(2)(i) table
569 579.
§ 726.302(c)(4)
January 23, 2019
January 15, 2020.
§ 726.302(c)(4)
$143
$146.
§ 726.302(c)(5)
January 23, 2019
January 15, 2020.
§ 726.302(c)(5)
$428
$436.
§ 726.30…
IRCCourt RulingsSep 25, 2019related by meaning
w that there is a
genuine dispute for trial that he had reasonable cause for not paying the unpaid tax
on the 2013 return made for him by RA Landadio. C. Summary Judgment
Rule 121(b) provides that, in the absence of a genuine dispute as to any
material fact, and if a decision may be rendered as a matter of law, we must…
IRCCourt RulingsJul 13, 1995related by meaning
deductible under the following sections of the Code:
(E) Dividends paid to an employee stock ownership plan that are deductible under section 404(k). The controversy in the instant case evolves from the treatment of section 404(k) dividends for purposes of computing earnings and profits. Based on the foregoing regulat…
IRCCourt RulingsOct 9, 1997related by meaning
ent with the intent of
DEFRA, and because it permissibly fills a gap created by sections
419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is
not impermissibly broader than sections 419 and 419A and,
accordingly, we hold that it is valid. Chevron…
IRCCourt RulingsFeb 6, 2024
…revenue agent’s report was
attached to the SFR. Cabirac, 120 T.C. at 172. In Rader v.
Commissioner, 143 T.C. 376, 382 (2014), aff ’ d in part, appeal dismissed
in part , 616 F. App ’ x 391 (10th Cir. 2015) , we s ummarized the
requirements of a section 6020(b) SFR : “ To constitute a section 6020(b)
SFR, ‘the return mu…
IRCCourt RulingsFeb 28, 2024related by meaning
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
IRCCourt RulingsSep 23, 2014
143 T.C. No. 11
UNITED STATES TAX COURT
DENNIS E. BOHNER, Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24166-12. September 23, 2014.
While P worked for the Federal Government, he participated in
the Civil Service Retirement System (CSRS). After P retired, he
received a letter explaining that he…
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 RulingsJul 21, 2014
T.C. Memo. 2014-143
UNITED STATES TAX COURT
KEITH ROBERTSON, Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20848-12. Filed July 21, 2014.
Keith Robertson, pro se.
Bradley C. Plovan, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LAUBER, Judge: The Internal Revenue Service (IRS or respon…
IRCCourt RulingsNov 26, 2014
143 T.C. No. 21
UNITED STATES TAX COURT
RSW ENTERPRISES, INC., Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
KEY LIME INVESTMENTS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 14820-11R, 14821-11R. Filed November 26, 2014.
Ps, domestic corporations, each established a retire…
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…