68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
IRCCourt RulingsMar 9, 2011
…y (city annuity). By letter dated
September 21, 1993, the city board approved a monthly annuity of
$389.67 payable to petitioner for life beginning on May 29, 1993.
The monthly payment under the city annuity increased by $11.69 in
September 1996 and in each September thereafter. The letter
stated that $27 in Federal in…
IRCCourt RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …
IRCRegulationsSep 17, 2024
…ionalaccountbalance afterwithdrawal 2028 $1,000,000 $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 …
IRCCourt RulingsAug 8, 2005related by meaning
Commissioner
, 83 T.C.
755, 791 n.28 (1984); Kahler v. Commissioner
, 18 T.C. 31, 34-35
(1952); Roberts v. Commissioner
, T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not
subject to substantial limitations, and petitioner makes no
contention otherwise. Consequently, we find…
IRCCourt RulingsJan 30, 2007
…. See Woodward v. Commissioner, 397 U.S. 572,
575 (1970); Lychuk v. Commissioner, 116 T.C. 374, 388-389 (2001);
Pappas v. Commissioner, T.C. Memo. 2002-127; see also secs. 1012,
1221(a). Therefore, we find that petitioners are not entitled to
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
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…
109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner IRCCourt RulingsDec 29, 1997
…2 -
of an involuntary conversion in Grant Oil Tool Co. v. United
States
, 180 Ct. Cl. 620, 381 F.2d 389, 395 (1967), which provides
that an involuntary conversion of property occurs for purposes of
the section 1231(a) gain and loss characterization rules when
property is "[rendered] * * * useless for the purpose[s] for
IRCCourt RulingsNov 21, 2023
…crease in the amount of a penalty asserted in his
answer. See Rader v. Commissioner , 143 T.C. 376, 389 ( 2014), aff’d in
part, appeal dismissed in part , 616 F. App ’ x 391 (10th Cir. 2015) ; see also
RERI Holdings I, LLC v. Commissioner , 149 T.C. 1, 38 – 39 (2017), aff ’ d
sub nom. Blau v. Commissioner, 924 F.3d 126…
IRCCourt RulingsNov 7, 1996related by meaning
in the
- 11 -
(...continued)
2085, 2481-2483. It was subsequently renumbered by sec.
1011A(g)(1)(A) of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3479. Because the
applicable regulation does not reflect the statutory renumbering,
the regulation appears as sec. 54.4981A-1T, Te…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsJun 17, 1997
…03,522 Compensation of officers 120,910 213,985 219,621 71,011 135,519
Salaries & wages 234,900 387,389 122,142 135,724 86,660
Pension, profit-sharing, plans 104,296 47,300 1,585-0 - - 0 -
Employee benefit programs-0 - - 0 - - 0-1,711 4,116
Ordinary income (loss) 471,158 232,440 371,926 (230,453) 213,508
Of the reporte…
IRCCourt RulingsFeb 28, 2024
…rst citing I.R.C. §§ 6501(a), 6503(a)(1); and
then citing B adaracco v. Commissioner, 464 U.S. 386, 389, 392 (1984)).
That is because, if the limitations period under section 6501 has not expired when the notice of deficiency is sent, it will automatically be suspended by section 6503(a)(1) and will pose no bar to the …
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 RulingsJul 13, 2010
… .80 $5,922 .00 $1,265 .2 8
2001 67,726 15,238 .35 16,931 .50 2,706 .5 4
2002 77,558 17,450 .55, 19,389 .50 2,591 .7 7
Sally R . O'Boyl e
Additions to tax under sec .
Year Deficiency 6651 (a) (1) 6651(a)(2) 665 4
2000 $76,162 $17,136 .45 $19,040 .50 $4,068 .2 0
2001 92,034 20,707 .65 23,008 .50 3,678 .0 1
2002 254,419 …
IRCCourt RulingsAug 1, 1996related by meaning
7 (1987); Hays Corp. v.
Commissioner
, 40 T.C. 436 (1963), affd. 331 F.2d 422 (7th Cir.
1964); see sec. 7442. The Court has no authority to disregard the express provisions of statutes adopted by Congress, even
where the result in a particular case seems harsh. See, e.g.,
Estate of Cowser v. Commissioner
, 736 F.2d 116…
IRCCourt RulingsJun 9, 2009
…loyee benefits, and we sustain respondent's determination .
E . Insuranc e
Petitioner claimed a $12,389 deduction for insurance on his
Schedule C . Petitioner testified that the insurance expense
mostly represented insurance that he paid on his automobile i n
IRCCourt RulingsOct 24, 2007
…ble year 1996. The 1996 joint return
reported adjusted gross income of $149,446, and tax due of
$27,389, which amount was paid by petitioner and Mr. Barrera.
After the closure of Financial Research Services,
petitioner’s lifestyle began to change, and from 1998 onwards,
she and her family were living less comfortably. …