IRCCourt RulingsNov 5, 1999
…0
3
for the Defined Benefit Plan reports total plan assets as of the
beginning of the plan year of $179,296 and $191,680 at the end of
the plan year. In addition, the Form 5500 reports $129,031 as
"any loan or extension of credit by the plan to the employer, any
fiduciary, any of the five most highly paid employees of …
IRCCourt RulingsNov 6, 2007
…of
all of the funds in his IRA, and Waddell & Reed issued nine
checks to Dr . Amarasinghe totaling $179,368 . Dr . Amarasinghe
endorsed each of these checks to Ms . Amarasinghe's attorney and
delivered them to her .
Dr . Amarasinghe and his spouse filed a joint 2002 Form 1040,
U .S . Individual Income Tax Return, in 20…
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 …
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…termination letters
178 .02 Elimination of remedial amendment cycle for individually designed plans
179
.03 Forms
179
.04 Application must include copy of plan and amendments
179
.05 Restatements required
180
.06 Section 414(x) combined plans
180
SECTION 12. WHEN MAY AN ADOPTER OF A MASTER AND PROTOTYPE OR VOLUME SUBMI…
IRCRegulationsSep 9, 2016
…ation, which is equal to 110% of the amount of guarantee payable by PBGC. That monthly amount is $1,179.75 ($1,072.50 × 1.1 = $1,179.75). Example 2.(i) Facts. The facts are the same as in Example 1, except that the participant is deceased and, immediately prior to the effective date of the suspension, the participant's…
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’ …
IRCCourt RulingsFeb 9, 2023related by meaning
uld have been had the taxpayer in the conduct of his
affairs been an uncontrolled taxpayer dealing at arm’s
length with another uncontrolled taxpayer. Regulations 86 Relating to the Income Tax Under the Revenue Act of
1934, at 122- 124 (Gov’t Prtg. Off. 1935). We have added emphasis to the
sentence that contains the ph…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
IRCCourt RulingsJan 29, 2019related by meaning
tiation rules. Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per
curiam, 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary Income Tax Regs., supra. These strict substantiation rules generally require the taxpayer to
substantiate with adequate records or by sufficient evidence corroborating the
taxpayer…
81 FR 25540 — Suspension of Benefits Under the Multiemployer Pension Reform Act of 2014 IRCFinal Rules (FR)Apr 28, 2016
…ation, which is equal to 110% of the amount of guarantee payable by PBGC. That monthly amount is $1,179.75 ($1,072.50 × 1.1 = $1,179.75).
Example 2.
(i)
Facts.
The facts are the same as in
Example 1,
80 FR 35262 — Suspension of Benefits Under the Multiemployer Pension Reform Act of 2014 IRCProposed Rules (FR)Proposed Jun 19, 2015
…ation, which is equal to 110% of the amount of guarantee payable by PBGC. That monthly amount is $1,179.75 ($1,072.50 × 1.1 = $1,179.75).
Example 2.
(i)
Facts.
The facts are the same as in
Example 1,
IRCCourt RulingsJul 18, 1968related by meaning
62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963).
In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
IRCCourt RulingsAug 17, 2015related by meaning
n 72(t) applies. The only exception they have alleged, by way
of partial offset to the additional tax, is the exception for "medical expenses."
- 10 - [*10] Petitioners have the burden of proving that this exception applies. See El v.
Commissioner, 144 T.C. __, __ (slip op. at 11-15) (March 12, 2015). Although
the IRS …
IRCCourt RulingsMar 31, 1997
…413. Of that amount, $57,607,463 was reflected on
petitioner's books as a TYE 8801 expense, and $44,179,950 was
reflected on Schedule M-1 as an adjustment to petitioner's book
income.
Of the $44,179,950 deducted by petitioner on the Schedule M1, $116,285 pertained to amounts contributed by Skaggs Alpha Beta
and Star Ma…
IRCCourt RulingsAug 8, 2000related by meaning
f sections 6212(a) and 6213(a).
- 5 -
Because this Court is a court of limited jurisdiction,
petitioner’s fraud argument is misplaced. The Court lacks jurisdiction to review or set aside the order of discharge
entered by the bankruptcy court. Therefore, petitioner’s
contention that the bankruptcy discharge is void beca…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…mber 27, 2007, Our Country paid $150,000 to National Advisors Trust. The Sterling Plan treated $124,179 of the $150,000 as an employer
contribution to the Our County Home, Inc. Welfare Benefit Plan. On March 21,
2008, Mr. Snyder gave Mr. Blake, in his capacity as Our Country's president, an
"annual valuation" for the 2…
IRCCourt RulingsNov 25, 2002related by meaning
(c)(2).
Thus, we sustain respondent’s determination on this issue.
C. Petitioner’s IRA Deductions
As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the
burden of proving his or her entitlement to the claimed
deductions.
18
Rule 142(a)(1); see New Colonial …
IRCCourt RulingsMar 31, 2015
thin the discretion of the Commissioner. Thompson v. Commissioner, 140
T.C. 173, 179 (2013) (citing section 301.6159-1(a), (c)(1)(i), Proced. & Admin. Regs.). If a settlement officer follows all statutory and administrative guidelines
and provides a reasoned and balanced decision, the Court will not reweigh the
equitie…