IRCCourt RulingsMar 7, 2019
…ur
analysis, see Jacobs, 1993 WL 495594, at *2-*3 (citing Spicer Accounting, Inc. v.
United States, 918 F.2d 90, 92 (9th Cir. 1990)); £ sec. 31.3121(d)-1(a)(3),
Employment Tax Regs. Indeed, the large difference between reported "wages"
and "director fees" in this case makes us all the more skeptical about the true
natu…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsFeb 2, 2022
… loss from
Morley of $8,515,404 relating to his pro rata share of Morley’s reported loss of
$26,887,918. In the notice of deficiency, respondent did not make a separate negative
IRCCourt RulingsJun 17, 1997
… at 1011 (quoting
International Tel. & Tel. Corp. v. General Tel. & Elec.
Corp.
, 518 F.2d 913, 917-918 (9th Cir. 1975)). In
reaching our conclusion, we followed the Supreme
Court's approach in United States v. American Trucking
Associations
, 310 U.S. 534, 60 S.Ct. 1059, 84 L.Ed.
1345 (1940). There the Court noted tha…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsMar 20, 1997
…s. Frank
Lyon Co. v. United States
, 435 U.S. 561, 580 (1978); James v.
Commissioner
, 87 T.C. 905, 918 (1986), affd. 899 F.2d 905 (10th
Cir. 1990). We agree with respondent, however, that the payments
of the processing fees by Dura-Craft to Northwest were shams.
Dura-Craft is a subchapter C corporation, and Northwest …
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsFeb 25, 2016
…6 and $22,476.41, respectively, and an enhanced accuracy-related
penalty under section 6662A of $63,918.33.
Also on June 9, 2011, respondent issued to petitioner a notice of deficiency
for 2005 determining a total deficiency in Federal income and excise tax of
$150,869, additions to tax under section 6651(a)(1) and (2)…
IRCCourt RulingsApr 20, 2017
…Lyle B. Press, for respondent.
THORNTON, Judge: The Internal Revenue Service (IRS) determined a
$37,918 deficiency in petitioners' 2011 Federal income tax. The issues for
decision are: (1) whether petitioners should receive a hardship waiver under
- 3 -
section 402(c)(3)(B) with respect to pension distributions that Mr…
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 RulingsMar 27, 1963
…_ 768.97
11_ __ 787.82
12_ __ 807.35
13_ __ 827.61
14_ __ 848.70
15_ __ 870.71
16_ __ 893.76
17_ __ 918.01
18_ __ 943.64
19_ __ 970.87
20_ 1, 000. 00
With respect to the payment of dividends the policy provided:
Dividends
IRCCourt RulingsNov 2, 1998
…result of the sale or
disposition, including a sale in foreclosure. Chilingirian v .
Commissioner
, 918 F.2d 1251 (6th Cir. 1990), affg. T.C. Memo. 1986463.
Section 1221(2) provides that real property used in a trade or
business is not a capital asset (and therefore a loss from the
IRCCourt RulingsSep 29, 1992
… for a period of about 5 years); cf. Jerome Mirza & Associates, Ltd. v. United States, 692 F. Supp. 918 (C.D. Ill. 1988), affd. 882 F.2d 229 (7th Cir. 1989) (reasonableness of actuarial assumptions reviewed where 73 percent of pension benefit obligation was funded in first year of plan).
IRCCourt RulingsJun 20, 2001
…al Bank account. He paid $3,258.33 in 1994 and
$2,235.36 in 1995.
The Lower Wetumpka Road house has 918 square feet and
contains four rooms and a kitchen and bathroom. Petitioner used
the large room in the front of the house as a waiting room during
tax filing season. It was also used by the Freedom Quilting Bee,
a 150…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
IRCCourt RulingsJul 8, 1980related by meaning
alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
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…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…,607
Per-Entity
331
331
Total:
Total Cost
164,098,348
3,061,442
34,613,730
66,284
Per-Entity Cost
1,918
3,314
132,457
3,314
SBA:
Threshold (in $ millions)
15.0
45.5
47.0
47.0
Per-Entity Cost as a Percentage of SBA Threshold
0.013%
0.007%
0.282%
0.007%
In response to comments, the Department has also conducted an analys…
IRCCourt RulingsAug 19, 2009
…NIO N
JACOBS, Judge : Respondent determined for 2005 a deficiency
in petitioners' income tax of $16,918 and an accuracy-relate
d
,penalty of $3,384 . After concessions by petitioners, the issues
before the Court are
: (1) Whether petitioners are liable for the
10-percent additional tax under section 72(t) with respect …
IRCCourt RulingsSep 9, 2010
…on or
14
- 7 -
ownership of the property .is being changed ." Bolton v .
MacDonald , 794 P .2d 911, 918 (Cal . 1990) (express declaration
creating a joint tenancy must declare interest being transferred
"to be a joint tenancy") . .-
Although the arrangement contemplated by the addendum
was already in . effect, the adde…