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 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…
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
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…
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…
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
…
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,…
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…
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…
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…
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…
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…
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
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 …
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…
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…
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…
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
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…
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…