IRCCourt RulingsNov 21, 2023
…nd that the weight of the evidence favors
petitioners here . See Diaz v. Commissioner, 58 T.C. 560, 564 (1972) (observing that
the process of distilling truth from the testimony of witnesses, whose demeanor we
IRCCourt RulingsJan 14, 2013★ strong match
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsMay 20, 2009related by meaning
flimited by sec . 72(p)(2)(A) to one .-
half of his retirement account balance .
1,
applies,,in this case . Petitioner is subject to the section 72(t) additional tax .
To ; reflect our disposition of the issues ,
Decision will be entere d
it,
for respondent .
r
IRCCourt RulingsJun 17, 1997
…o. 2546-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1) 6662(a)
1990 $17,820 --- $3,564
1991 10,263 --- 2,053
Young & Young, Ltd.(Young & Young), docket No. 5754-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1)
6662(a)
1989 $12,744 $637 $2,549
Howard S. Young & Elaine P. Young (the Youngs…
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…
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 …
IRCCourt RulingsNov 1, 2005related by meaning
ficiency for the years in
issue. Respondent determined that petitioner was liable for
additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also
determined that petitioner was liable for additions to tax under
sections 6651(a)(1) and 6654(a), as set out ab…
IRCRegulationsSep 17, 2024
…000 $400,000 2029 954,545 $408,000 $404,000 $18,957 389,043 2030 909,306 396,824 392,933 19,260 377,564 2031 864,291 385,115 381,339 19,462 365,653 2032 819,740 372,966 369,310 19,765 353,201 2033 775,430 360,265 356,733 19,955 340,310 2034 731,620 347,116 343,713 20,257 326,859 Table 5 to Paragraph (m)(4)(ii)(A) Year …
IRCCourt RulingsOct 10, 1979related by meaning
Tannenwald, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner for 1971, 1972, and 1973 in the respective amounts of $3,576.58, $4,052.04, and $3,912 together with negligence penalties under section 6653(a). The negligence penalties have been conceded by respondent, and capital loss adjus…
IRCRegulationsDec 23, 2021
…rand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to section 564 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360bbb-3), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes drugs that the U.S. Food and…
IRCCourt RulingsMar 5, 1987related by meaning
tions and are administered in a manner identical to the manner in which the payments to article III judges in regular active service are administered. Accordingly, petitioners are not here receiving the double tax benefit Congress sought to prevent by section 219(b)(2)(A).
Having decided that petitioners are entitled t…
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
…d compensation
liability is taken into account. See JP Morgan Chase & Co. v.
Commissioner, 458 F.3d 564, 568 (7th Cir. 2006) , aff’g in part , vacating
in part , and remanding Bank One Corp. v. Commissioner, 120 T.C. 174
(2003) .
As discussed in the previous section, section 404(a)(5) is the
applicable Code provision t…
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…
IRCCourt RulingsApr 20, 2017related by meaning
5).
28See, e.g., Priv. Ltr. Rul. 201535029 (Aug. 28, 2015) (waiver granted to
taxpayer suffering from "mild cognitive impairment and moderate clinical depression", who was "not aware that he did not roll over Amount 1 to another
IRA until his tax return for 2013 was being prepared"); Priv. Ltr. Rul. 201323044
(June 7, …
IRCCourt RulingsDec 23, 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. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCCourt RulingsApr 11, 2012
… 2003,
the accumulation value4 of Dr. and Mrs. White's Indianapolis Life policies was
$642,220.87 ($564,655.36 for Dr. White's and $77,565.51 for Mrs. White's). The
Indianapolis Life annual report indicates that as of September 15, 2003, the policy
on Dr. White's life had a guaranteed cash and surrendër value of $127,9…
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…