IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsApr 2, 2020
…
1. Adjustments to income e End Petfod Emi Period End
a NOL Carryback-Ronald Goldberg from 2005 415,334.00
b. NOL Carryback- Gail Goldberg 2006 {1,271,781.00)
c. Sch E-Ine/Loss-Wireless 645,162.00
d. mon carryback-Ronald 2006 (1,018,228.00)
e. NOL Carryforward-2003 Recapture 415.334.00 ..
f. Other Income- NICHE 394,091…
Notice 2026-13 — Safe Harbor Explanations – Eligible Rollover Distributions IRCNoticesFeb 2, 2026
…02(f) notice requirements to PLESA distributions.
g. Qualified Long-Term Care Distributions Section 334 of the SECURE 2.0 Act amended section 72(t)(2) of the Code by adding section 72(t)(2)(N) to provide a new exception to the 10% additional tax for qualified long-term care distributions, which are generally distributi…
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
IRCCourt RulingsAug 30, 2006related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
T.C. Summary Opinion 2006-136
UNITED STATES TAX COURT
LARRY J. AND CATHERINE E. FRANCE, Petitioners v
.
COMMISSIONER…
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…
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
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 RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
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…
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance IRCFinal Rules (FR)Oct 31, 2016
…lth Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. 19. Section 148.102 is amended by adding a sentence at the end of paragraph (b) to read as follows:
§ 148.102
Scope, applicability, and effective dates.
(b) * * * Notwithstanding the previous sentence, the definition of “short-term,…
IRCRegulationsMay 18, 2016
… does not claim as deductions any other items listed in section 62. A's gross income for 1975 is $9,334. On April 1, 1976, $107 is distributed to A from his individual retirement account. As of such date, the balance of the account is $1,498 [$1,605 − $107]. There were no other distributions from the account as of such…