IRCCourt RulingsFeb 9, 1998related by meaning
this case of most of the
enumerated badges of fraud. Accordingly, petitioner is liable
for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Where prepayments of
tax do not equal the percentage of total liabil…
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
IRCCourt RulingsJun 23, 2025related by meaning
Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of
$2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183
( Ct. Cl. 1982) (“The determination of where income is derived or
‘sourced’ is generally of no mome…
IRCCourt RulingsApr 20, 2017related by meaning
; Bruhwhiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M.
(CCH) 1071, 1074.
Petitioner has repeatedly advanced numerous frivolous positions in this Court. These include assertions that he has no obligation to file Federal income
tax returns, that he is the executor of the estate of an artificial person, and that
res…
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…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCProposed Rules (FR)Proposed Oct 29, 2018
…ddition, 1/12 of the product of 9.86 percent and A's household income is $230 ($28,000 × .0986 = $2,761; $2,761/12 = $230). Because A's required HRA contribution of $300 exceeds $230 (1/12 of the product of 9.86 percent and A's household income), the HRA is unaffordable for A for each month of 2020 under paragraph (c)(…
IRCCourt RulingsJan 5, 2017related by meaning
ccuracy-related penalty under
section 6662.
OPINION
I. Preliminary Matters
Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree.
Generally, the Commissioner's determinations in a notice of deficiency are
presumed correct…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…to be treated as the owner of all or a portion of the trust under §§ 673 to 677. (19) Sections 101, 761, and 7701.—Certain Death Benefits; Terms Defined; Definitions.—Whether, in connection with the transfer of a life insurance policy to an unincorporated organization, (i) the organization will be treated as a partners…
IRCCourt RulingsMar 31, 2015related by meaning
Commissioner's determination for abuse of discretion. E2, Sego v.
- 18 -
[*18] Commissioner, 114 T.C. at 610. The Appeals Office abuses its discretion when its exercise of discretion is arbitrary, capricious, or without sound basis in
fact or law. Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005), aff'd, 469
F.3d 2…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
IRCCourt RulingsSep 24, 2002related by meaning
titioner is not
liable for the sec. 6662 penalty.
3
S.K. apparently stands for Smoothie King, which we gather
was the trade name of a product.
OPINION DAWSON, Judge
: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(3) and
Rules 180, 181, and 182.
1
The Court agrees with and…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4… IRCNoticesObsolete Dec 26, 2007
…ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005
…ALTH PLANS
Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
IRCCourt RulingsMar 12, 2015related by meaning
as
either unable to pay the tax or would suffer an undue hardship if he or she paid on
the due date. See sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Respondent concedes that he has not met his burden of production on this
issue because he failed to introduce into evidence the substitute for return that he
purportedly…
IRCCourt RulingsAug 18, 2015
…6, 2010, the day petitioners made their withdrawal, the cash
value of the ING annuity contract was $761,256. Petitioners thus had $186,302 of
"income on the contract" (cash value of $761,256 minus their "investment in the
contract" of $574,954). Because the amount of the withdrawal, or $525,000, ex5When Allstate passed…
IRCCourt RulingsJun 9, 2005
…Taxable interest 71
9 Ordinary dividends 89
13 Capital gain 966
16a Total pensions and annuities 96,761
16b Taxable amount 96,761
34 Adjusted gross income 187,214
36 Itemized deductions 53,512
53 Tax on IRAs,... 6,323
On Schedule A, Itemized Deductions, petitioner reported the
following relevant deductions and expenses…
IRCCourt RulingsJan 6, 1997related by meaning
etitioners are liable for an
accuracy-related penalty of $4,870 pursuant to section 6662(a)
for 1991. Section 6662 imposes a 20-percent penalty on any portion of any underpayment that is attributable to any
substantial understatement of income tax. Sec. 6662(a)(2),
- 14 -
(b)(2). Respondent based the determination of t…