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83 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 75 FR 27122 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26 Under the Patient Protection and A…
    IRCFinal Rules (FR)May 13, 2010
    …64 1.42 1.21 Incremental Premium Cost Per Individual Coverage $3,670 $3,800 $4,000 $3,380 $3,500 $3,690 $3,220 $3,340 $3,510 Impact on Group Insurance Premiums (%) 0.5 0.7 0.7 0.7 1.0 1.0 1.2 1.2 1.1 ( printed page 27130)
  2. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …rn Return Respondent Dispute Advertising -0- $51.54 $26.84 $24.70 Auto expense $2,507.67 5,503.09 2,690.69 2,812.40 Insurance 155.00 155.00 155.00 -0Legal & prof. 432.00 2,635.05 2,635.05 -0Mortg. interest 6,503.89 6,503.89 6,503.89 -0Repairs 4,112.10 5,487.10 5,487.10 -0Taxes 220.00 435.43 435.43 -0Utilities 3,837.35 …
  3. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …ies into a taxpayer’s subjective 31 [* 31] motivations. See Hernandez v. Commissioner , 490 U.S. at 690 – 91. If a transaction is structured such that it is understood that the taxpayer’s money or property will not pass to the charitable organization unless the taxpayer receives a specific benefit in return —or the tax…
  4. T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 23, 2022
    …s gain on the 2012 s ale Hoops reported a total amount realized of $419,394,032, consisting of $200,690,000 of cash , $218,704,032 of liabilities assumed by Buyer , and oth er adjustments. Hoops reported an adjusted basis of $120,370,493 in the assets that it sold to Buyer. Thus, Hoops recognized gain of $299,023,539 o…
  5. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
  6. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    ified retirement plan during 2002, before he had attained age 59-1/2 . Thus, even if the additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imp…
  7. 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…
  8. 77 T.C. 477 — Chapman v. Commissioner
    IRCCourt RulingsAug 24, 1981related by meaning
    in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
  9. T.C. Memo. 1996-189 — Marcus Wayne & Judith Caroline Ramsey v. Commissioner
    IRCCourt RulingsApr 18, 1996
    …curre ntly deductible items from capital expenditures. C ommissioner v. Tellier , 383 U.S. 687, 689-690 (1966). An expense is necessary if it is appropriate and helpful to the operation of the taxpayer’s trade or business. Carbine v. Commissioner
  10. T.C. Memo. 2012-195 — Neil J. Yosinski v. Commissioner
    IRCCourt RulingsJul 12, 2012
    …ckering, but the construction was finished in 2011. In October 2011 the marital house was sold for $690,000. Because respondent had an outstanding 1 enÀgainst the marital house with respect to petitioner and Colleen Gloce i's unpaid tax liability for 2006, the liability at issue was fully paid from the praceeds. Áfter …
  11. 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…
  12. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  13. T.C. Memo. 2009-263 — James A. & Linda A. Willhite v. Commissioner
    IRCCourt RulingsNov 18, 2009
    …otice, responden t determined that petitioners are liable for the 10-percent additional tax on $369,690 .98 of the 2004 IRA distribution that M Willhite received during 2004 . 2 2In determining in the 2004 notice the 10-percent additional tax for which petitioners are liable for taxable year 2004, respondent reduced th…
  14. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    te minus amounts received before such date to the extent excludible from gross income. Sec. 72(e)(6). The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to him of income and as the parties have agreed is subject to the 10-percent premature distribution tax und…
  15. T.C. Memo. 2006-47 — Diep N. Hoang v. Commissioner
    IRCCourt RulingsMar 20, 2006
    … 624, 631-632 (7th Cir. 1989), affg. T.C. Memo, 1987-295; Geiger v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159; Tokarski v. Commissioner, 87 T.C. 74, 77 .(1986). Accordingly, we sustain respondent's determination regarding
  16. 54 T.C. 702 — Republic Engineers, Inc. v. Commissioner
    IRCCourt RulingsMar 31, 1970related by meaning
    OPINION Quealy, Judge: Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
  17. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  18. T.C. Memo. 1999-240 — Marty M. & Marilee D. Morin v. Commissioner
    IRCCourt RulingsJul 22, 1999related by meaning
    ursuant to section 72(t). - 6 - Section 72(t) provides for a 10-percent additional tax on the taxable amount of an early distribution from a qualified retirement plan. Section 72(t)(2) provides exceptions to the tax for certain types of distributions. Petitioners did not offer any evidence at trial related to this issu…
  19. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    … Deficiency Sec . 6651(a)(1) Sec . 6651(a)(2) Sec . 665 4 2002 $9,340 $388 .75 2003 9,354 -- 2004 9,690 1,059 .50 1 $245 .83 241 .15 266 .6 9 1 "The amount of the addition to tax per IRC 6651(a)(2) cannot be determined at this time but an addition to tax of 0 .5 percent will be imposed for each month, or fraction there…
  20. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter 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 which is includible in gross income. - 9 - 5 See also …