ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsSep 22, 1998related by meaning
te minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax und…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
IRCCourt RulingsFeb 28, 2024related by meaning
by the decision of the Tax Court which has become final shall be assessed and
shall be paid upon notice and demand from the Secretary .”). In short,
5 For a discussion of the disputed issues of fact on this point, see the Order
issued by the Court on April 8, 2019, denying each party’s Motion for Partial Summary
Judgme…
T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner IRCCourt RulingsJun 17, 1998related by meaning
s Revenue Act of 1988
(TAMRA), Pub. L. 100-647, sec. 5031(a), 102 Stat. 3342, 3368) is
effective for transactions with valuation dates after April 30, 1989. TAMRA sec. 5031(c), 102 Stat. 3369. Generally, the
valuation date for gift tax purposes is the date upon which the
gift is made. Sec. 25.7520-1(b)(1)(ii), Gift Tax…
IRCCourt RulingsSep 25, 2019related by meaning
appreciate the difficulties that incarceration imposed on petitioner in
obtaining information that might show that he had deductible expenditures for 2013 that exceed the $6,100 standard deduction accorded him by respondent,
petitioner has not--either in his defense to the motion or in his justification for his
two co…
81 FR 2086 — Extension of Import Restrictions Imposed on Archaeological Material Originating in Italy and Representing the Pre-Classical, Classical, and Imperial Roman Peri… IRCFinal Rules (FR)Jan 15, 2016related by meaning
notice of proposed rulemaking is required, the provisions of the Regulatory Flexibility Act (5 U.S.C. 601
et seq.) do not apply.
Executive Order 12866 It has been determined that this rule is not a significant regulatory action under Executive Order 12866.
Signing Authority
This regulation is being issued in accordance…
IRCCourt RulingsMay 25, 2005related by meaning
T.C. Memo. 2005-124
UNITED STATES TAX COURT
HENRY USCINSKI AND JACQUELINE USCINSKI, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1467-03. Filed May 25, 2005.
Henry Uscinski and Jacqueline Uscinski, pro sese.
Scott A. Hovey
, for respondent.
MEMORANDUM OPINION
GERBER, Chief Judge
: This case i…
IRCCourt RulingsDec 18, 2012related by meaning
te returns for the subject years. We sustain respondent's
determinations (as amended) as to the imposition of the section 6651(a)(1)
additions to tax. Respondent concedes that the section 6654 addition to tax does not apply
for 1992. As to the remaining years, the record does not establish that any of the
referenced ex…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-263
UNITED STATES TAX COURT
RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v
.
COMMISSI…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsMar 15, 2004related by meaning
t 22, 2001,
respondent issued to petitioners a notice of deficiency
determining that they were liable for this additional tax in the
amount of $2,000. Discussion
I. General Rules
In general, section 408 governs the treatment of IRAs.
Specifically, section 408(d) provides that distributions from an
IRA are taxable in th…
IRCCourt RulingsJun 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
IRCCourt RulingsDec 11, 2003related by meaning
ks to collect the 10-percent additional tax on
early distributions from qualified retirement plans.
Once again, other than his self-serving testimony, petitioner has offered no evidence in support of his position, no
bank statements or other evidence that would corroborate his
assertion that the tax was withheld or tha…
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 RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsAug 15, 1996related by meaning
c.
Year
6651(a)(1)
1985 $ 813
1986 1,123
1987 1,403
1988 1,529
1989 1,581
1990 1,539
Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text.
The primary issue for decision is whether petitioner engaged
in a prohibited transaction so as to be subject to the first-tier
excise t…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …