IRCCourt RulingsJun 14, 2012related by meaning
ed work in her capacity as Yolo's employee or officer. Consistent with
our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties
A. s Burden of Proof
Respondent bears the burden of production with regard to the section
6651(a)(1) and (2) additions to tax and the …
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…
IRCCourt RulingsApr 18, 1996
… letter from Bancsure to petitioner dated Mar. 31,
1989, refers to a total severance payment of $61,812.50, of which
$6,812.50 represented expense reimbursement and pension payments.
The letter makes no allocation of the $6,812.50 as between
expense reimbursement and pension payments.
established a SEP for petitioner’s…
34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960related by meaning
n this report.
All statutory references herein are to the Internal Revenue Code of 1939, unless otherwise specified.
SEC. 291. FAILURE TO PILE RETÜRN. (a) In ease of any failure to make and file return required by this chapter, -within the time prescribed by law or prescribed by the Commissioner in pursuance of law, un…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
IRCCourt RulingsApr 2, 2024related by meaning
an incident
date. To determine whether Congress has spoken to this question, we
consider the “plain” and “literal” language of the statute itself, the specific context in which the language is used, and the broader context
of the statute as a whole. See Robinson v. Shell Oil Co. , 519 U.S. 337,
341 (1997); Allen v. Uni…
IRCCourt RulingsSep 9, 1998related by meaning
s and claims against a
debtor's estate. Sec. 507(a)(8) of the Bankruptcy Code provides
a priority for unsecured claims of governmental units for taxes measured by income or gross receipts within the time periods set
forth therein.
by respondent's motion for the reason explained below. However,
because no justiciable is…
IRCCourt RulingsJan 26, 2006related by meaning
ate are treated as payments not
received as an annuity and are taxable. Sec. 72(e)(2)(A).
There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is
not includable in income. The Court and respondent encouraged
- 10 -
petitioner to provide sufficient in…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…his figure is calculated by multiplying the annual cost per user after the file-size reduction ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600.
Back to Citation
210.
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 …
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013related by meaning
llion.
(1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due. (2) If a contributing sponsor or the ultimate parent completes and submits Form 200 in accordance with this section, PBGC will consider the notification requirement in s…
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 …
IRCCourt RulingsAug 1, 2005related by meaning
his annuity policies. As
stated earlier, section 72(e)(5) applies to the surrender of an
annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a
distribution upon the complete surrender of an annuity contract
is includable in gross income to the exten…
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 RulingsApr 19, 2004related by meaning
longed to petitioner when he
filed his bankruptcy petition is still encumbered in rem by a
Federal tax lien. Respondent argues that a State law cannot operate to divest or exempt petitioner’s section 401(k)
retirement account from the Federal tax lien. Respondent
contends that collection by levy is appropriate. We agre…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
IRCCourt RulingsSep 29, 2022related by meaning
riality in a constitutional sense, petitioner’s argument is
without merit.
Consequently, we uphold respondent’s determinations of
unreported income.
7 II. Additional tax under section 72(t)
For 2013 r espondent determined that petitioner is liable for an
a dditional tax of $430 under section 72(t). Section 72(t)(1) imp…
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
added to the aggregate unpaid balance of all preceding such payments for which payment was not made when due (including interest), exceeds $1 million. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due.
(2) If a contributing spo…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
IRCRegulationsSep 9, 2016
…st rate and 5.82% for the second segment interest rate. (ii) A shortfall amortization base of −$379,812 is established for 2016, which is equal to the $2,500,000 funding target, reduced by the sum of $2,450,000 of assets, $316,696 (the present value of the remaining installments with respect to the 2015 shortfall amort…