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88 documents · 0.30sAllIRCERISAPBGCJoint Board
  1. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ter 177 SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR VOLUME SUBMITTER PLANS? 178 .01 Scope 178 .02 Determination letter for adoption of volume submitter plan 178 .03 Timing of determination letter applications for adopting employers of pre-approved plans 179 SECTION 14.WHAT ARE THE DETERMINATION …
  2. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
  3. IRCCourt RulingsAug 3, 1979related by meaning
    atutory discrimination will not be set aside if any state of facts reasonably may be conceived to justify it.” McGowan v. Maryland, 366 U.S. 420, 426. “Normally, a legislative classification will not be set aside if any state of facts rationally justifying it is demonstrated to or perceived by the courts.” United State…
  4. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012
    …oidance is the principal purpose for the acquisition. See Capri, Inc. v. Commissioner, 65 T.C. 162, 178 (1975); Plains Petroleum Co. v. Commissioner, T.C. Memo. 1999-241; see also sec. 1.269-3(a), Income Tax Regs. In the context of section 269, "principal purpose" means that the evasion or avoidance purpose must exceed…
  5. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    itioner and his wife owned 100 percent of the Garrahan Agency, and since petitioner is a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G). 3. Conclusion The Garrahan Agency is a disqualified person under section 4975(e)(2), and thus it and petitio…
  6. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  7. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968
    … paid: 2/9/63 2/12/64 Tax year_ 1963 1964 Prorata share of contributions paid: Edward B. Fleitz_ 2, 178. 90 2, 622. 52 James J. Fleitz_ 1, 694. 70 1, 939. 95 Robert J. Fleitz_ 2, 178. 90 2, 622. 53 Total_ 6, 052. 50 7, 185. 00
  8. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
  9. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    ion of penalties. Florida Hospital Trust Fund v. Commissioner, * * * 103 T.C. 140 (1994). The issue in the present cases is not whether this Court has jurisdiction over different aspects of petitioners' tax status, but whether we have jurisdiction over the section 6652(c)(1) penalty. None of the above-listed instances …
  10. T.C. Memo. 2017-178 — Dean Russell Cates & Teresa Stinnett Cates v. Commissioner
    IRCCourt RulingsSep 13, 2017
    26 SD T.C. Memo. 2017-178 UNITED STATES TAX COURT DEAN RUSSELL CATES AND TERESA STINNETT CATES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25934-14. Filed September 13, 2017. Dean Russell Cates and Teresa Stinnett Cates, pro sese. Brianna B. Taylor, John W. Sheffield, III, Ashley Y. Smith, a…
  11. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  12. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …ading lies within the sound discretion of the Court. Estate of Quick v. Commissioner, 110 T.C. 172, 178 (1998). In determining whether to allow a proposed amendment, the Court must consider (among other things) whether an excuse for the delay exists and whether the opposing party would suffer unfair surprise, substanti…
  13. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    …ed by attorney’s fees and costs) during the 1992 tax year. Of that amount, State Farm reported $283,178 on Form 1099-MISC and the remaining $425 on - 5 - Form W-2. State Farm negotiated and reported the $283,178 of settlement proceeds on Form 1099-MISC as the amount it would have paid petitioner if she had become its i…
  15. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980related by meaning
    . Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
  16. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …ponsored insurance and 1.8 million individuals had other private insurance in New York State, while 178.4 million individuals had employer-sponsored insurance and 34.8 million individuals had other private insurance nationally. The Departments estimates New York accounts for 5.8 percent of the private insurance market …
  17. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …n, this Court has continued to cite Larotonda as binding precedent. See Rodrigues , T.C. Memo. 2015-178, at * 11; Swanton v. Commissioner, T.C. Memo. 2010-140, 99 T.C.M. (CCH) 1576, 1578 ; Schroeder, 78 T.C.M. (CCH) at 568; Murillo , 75 T.C.M. (CCH) at 1566; Pilipski v. Commissioner , T.C. Memo. 1993-461, 66 T.C.M. (CC…
  18. T.C. Summary Opinion 2001-178 — Dennis J. Lawless v. Commissioner
    IRCCourt RulingsNov 28, 2001
    T.C. Summary Opinion 2001-178 UNITED STATES TAX COURT DENNIS J. LAWLESS, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1926-00S. Filed November 28, 2001. Dennis J. Lawless, pro se. John E. Glover , for respondent. THORNTON, Judge : This case was heard pursuant to the provisions of section 7463 …
  19. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    principles and to deter the waste of judicial resources. See Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of the potential implications of continuing to assert frivolous and groundless arguments. For…
  20. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    T.C. Memo. 2015-178 UNITED STATES TAX COURT GARY WAYNE RODRIGUES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27277-11L. Filed September 10, 2015. Gary Wayne Rodrigues, pro se. Peter R. Hochman, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: This case arises from a pet…