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85 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    … Tax Under Section 72(t) on the Distribution From Petitioner's Retirement Plan In general, section 4974(c) defines qualified retirement plans as including individual retirement accounts (IRA). Section 408 governs the treatment of IRAs. Specifically, section 408(d) provides that distributions from an IRA are generally t…
  2. PLR 201211001 — Eligible Deferred Compensation Plan Defined
    IRCPrivate Letter RulingsMar 16, 2012
    974. If the Plan is modified, this ruling will not necessarily remain applicable. This ruling is directed onl y to Employer and applies to the Plan as submitted by a transmittal letter dated March 7, 2011, and the provisions of the amended and restated version provided on October 26, 2011. Section 6110(k)(3) of the Cod…
  3. 29 T.C. 22 — Loeb v. Commissioner
    IRCCourt RulingsOct 11, 1957
    …f ownership and control of the policy belong to her. Annual premiums on the Prudential policy were $974,40 for the first 3 years and $1,137.30, thereafter. On April 5,1941, Bessie, as “applicant,” and Clarence, as the proposed insured, made application to the John Hancock Mutual Life Insurance Company of Boston, Massac…
  4. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    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 T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  5. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …104 (4th Cir. 1995); Pro . & Exec. Leasing, Inc. , 89 T.C. at 232; Simpson v. Commissioner, 64 T.C. 974, 984– 85 (1975) . 17 [* 17] and Arjun. The record establishes that petitioners pursued that goal. Although Veerendra and Arjun were in college in 2014, petitioner husband credibly recounted assigning them research ta…
  6. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  7. T.C. Memo. 2011-2 — Michael C. Hollen, D.D.S., P.C. v. Commissioner
    IRCCourt RulingsJan 4, 2011
    … tax treatment:under section 501(a)). In addition, 'the Employee Retirement Income Security Act of 1974, Pub. L. 93-406,- sec. 402(a) (1) 88 Stat. 875; requires that the plan be in writing. See also sec. 1.401-1(a) (2), Income Tax"Regse Congress established the writing requirement-so that every employee may, -on examin…
  8. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  9. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …1988); Burnetta v. Commissioner , 68 T.C. 387, 397 (1977); Simpson v. Commissioner , - 16 - 64 T.C. 974, 984 (1975); Packard v. Commissioner , 63 T.C. 621, 629 (1975); sec. 1.1402(c)-1, Income Tax Regs. Relevant factors courts consider to determine whether an employer/employee relationship exists between the service pr…
  10. 74 T.C. 651 — Judd v. Commissioner
    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…
  11. T.C. Summary Opinion 2002-15 — Bryan K. Gauthier v. Commissioner
    IRCCourt RulingsFeb 15, 2002related by meaning
    tioner’s 1998 Federal income tax and an addition to tax under section 6651(a)(1) of $3,433 and $321, respectively. After concessions by the parties, 2 the issues are (1) whether petitioner is liable for the additional tax under section 72(t) and (2) whether petitioner is liable for the addition to tax under section 665…
  12. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    …tax of 10% on the portion of a distribution from a qualified retirement plan as defined in section 4974(c) (e.g., an IRA) that is includable in gross income, unless the distribution falls under one of the exceptions prescribed in section 72(t)(2). Petitioners assert that the additional
  13. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …ove factors must be shown by a preponderance of the evidence. Armes v. Commissioner , 448 F.2d 972, 974 (5th Cir. 1971), affg. in part and revg. T.C. Memo. 1969-181. We explained the mechanics of how the burden of going forward with the evidence works and when it shifts in Adler v. Commissioner , 85 T.C. 535, 540 (1985…
  14. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    …ional tax of 10 percent of amounts received from qualified retirement plans (as defined in section 4974(c)) that are includable in gross income. Section 72(t)(2) contains certain exceptions. Respondent determined that such additional tax was due from petitioner on account of his receipt of the 1992 distribution and the…
  15. T.C. Memo. 1999-174 — Chrys L. Udoh v. Commissioner
    IRCCourt RulingsMay 21, 1999
    … 655 Office expense 1,485 Travel 2,156 Other expenses: Beeper, phone $849 Subscriptions & law books 974 Clothing, shoes & maintenance 728 Seminars 593 Continuous legal education & examination fees 1,935 5,079 Total 14,897 Schedule C: "Clothing And Accessories" Cost of goods sold $3,128 Expenses: Advertising 455 Supplie…
  16. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …24 241,922 Profit-sharing 9,161.48 13,960.19 19,348.99 27,238 36,032 Total 71,232.48 108,307.69 149,974.93 210,862 277,954
  17. T.C. Memo. 1999-240 — Marty M. & Marilee D. Morin v. Commissioner
    IRCCourt RulingsJul 22, 1999
    …ceived a retirement account distribution from Common Sense Shareholder Services in the amount of $1,974. Mr. Morin had not yet attained the age of 59½ at the time he received this distribution. OPINION Section 61 defines gross income as all income from whatever
  18. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  19. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …ity, Inc., docket No. 11520-11 Accuracy-related penalty Year Deficiency Sec. 6662(a) 2006 $9,872 $1,974 2(...continued) dollar. We interchangeably use the terms "insurance contract" and "insurance policy" for convenience and do not intend to signify a distinction by our use of
  20. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1996-450 UNITED STATES TAX COURT THEODORE SOURIS, P.C., A DISSOLVED CORPORATION, AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST OF THEODORE SOURIS, P.C., Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 639-95. F…