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89 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    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…
  2. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  3. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018
    …. 1992-153; see also Weimerskirch v. Commissioner, 596 F.2d 358, 360 (9th Cir. 1979), rev'g 67 T.C. 672 (1977). Once the IRS has produced evidence linking the taxpayer with an
  4. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
  5. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    ith respect to our Opinion. In our Opinion, we held that petitioner may not deduct in a single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19) months. In the Motion petitioner alleges that the Court erred in that this holding contradicts 20 years…
  6. 84 FR 67186 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 9, 2019
    …um 3 if monthly benefit at URA is— High 4 if monthly benefit at URA is greater than— From— To— 2021 672 672 2,839 2,839 2022 688 688 2,905 2,905 2023 704 704 2,971 2,971 2024 720 720 3,040 3,040 2025 736 736 3,110 3,110 2026 753 753 3,181 3,181 2027 771 771 3,254 3,254 2028 788 788 3,329 3,329 2029 806 806 3,406 3,406 …
  7. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  8. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
  9. T.C. Memo. 2008-201 — Joseph R. Banister v. Commissioner
    IRCCourt RulingsAug 27, 2008
    …ncy . See Weimerskirch v . Commissioner , 596 F .2d 358, 360-362 (9th Cir . 1979), revg . 67 T .C . 672 (1977) . In Weimerskirch , the Court of Appeals for the Ninth Circuit imposed the evidentiary foundation requirement in light of the Commissioner's unsupported assertion that the taxpayer had earned $30,000 selling i…
  10. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  11. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  12. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …eturns reported the following information: 1988 1989 1990 1991 1992 Total income $440,673 $571,125 $672,543 $622,323 $639,859 Compensation of officers 164,000 327,000 450,000 315,000 367,000 Salaries & wages 86,551 36,600 42,656 23,247-0 - Pension, profit-sharing, plans 73,462 77,769 93,556 160,351 102,506 Employee ben…
  13. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …uted at the end of the 5-year period. * * * [H. Conf. Rept. 97-760, at 619 (1982), 1982-2 C.B. 600, 672.] The above-quoted statement from the conference report sets forth Congressional intent regarding the treatment of loans that are subject to the 1982 Act, that is, loans made after
  14. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …istributed at the end of the 5-year period." H. Conf. Rept. 97-760, at 619 (1982), 1982-2 C.B. 600, 672 (emphasis added). Respondent further argues that any interest accruing after the 5-year period but before the - 22 - 9 Respondent's argument assumes that Milo Chapman and David Christie were participants in the Plan …
  15. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …esolution of the issues that we address herein. Year Deficiency Accuracy-Related Penalty 1996 1 $15,672 $3,134.40 1997 1 15,832 3,166.40 1 The deficiency determined by respondent for each year included a deficiency of $120 in Federal excise tax under sec. 4973(a). The issues remaining for decision 2 are: (1) Do payment…
  16. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …g as evidence of the practice of the Commissioner- . See Hanover'Bank v . Commissioner , 369 U .S . 672, 686 (1962) ; Maadalin v . Commissioner ,' -T .C . Memo . 2008-293 n .7 . - .10 - Minors Act is treated as held by the disabled person or child . Petitioner's other argument is that an IRA is a grantor trust that qua…
  17. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  18. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …ng activity, see Weimerskirch v. Commissioner, 596 F.2d 358, 361-362 (9th Cir. 1979), rev'g 67 T.C. 672 (1977). The requisite evidentiary foundation is minimal and need not include direct evidence. See Rapp v. Commissioner, 774 F.2d 932, 935 (9th Cir. 1985); Banister v. Commissioner, T.C. Memo. 2008-201, a_ff'd, 418
  19. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    …ng to such taxes. See Shaw v. United States, 331 F.2d 493, 494-495 (9th Cir. 1964) (involving sec. 6672); Wilt v. Commissioner, 60 T.C. 977, 978 (1973)(same). To reflect the foregoing, An appropriate order will be entered. Jorj had previously reported tip income of $480 for purposes of the FICA tax; however, she did no…
  20. T.C. Memo. 1996-231 — Charles E. King v. Commissioner
    IRCCourt RulingsMay 22, 1996
    … 1 Respondent determined a deficiency in petitioner's Federal income tax for 1990 in the amount of $672. The issues are: (1) Whether petitioner is entitled to deduct expenses attributable to a home 2 office under section 280A; (2) whether petitioner is entitled to claim a deduction for health insurance premiums; and (3…