IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsOct 10, 1979related by meaning
es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsNov 5, 1999
… participants:
Mortgages -0- -0Other 152,112
-0-
Total investments 152,112
137,270
Total assets 191,680 179,628
Liabilities
Total liabilities -0-
-0-
Net assets 191,680 179,628
The Form 5500 also reports expenses of $20,653 which represented
distribution of benefits directly to participants.
The Schedule B for the year…
IRCCourt RulingsDec 23, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCCourt RulingsAug 12, 1998★ strong match
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsMay 23, 1996
…90
1991
PERS $3,649.32 $3,748.32 $3,847.32
U.S. Army 13,939.68 14,736.99 15,581.40
OPM 11,447.84 13,680.00 14,412.00
Total $29,036.84 $32,165.31 $33,840.72
During the year 1989, after having his annuity distributions
reduced as discussed above, petitioner received annuity benefits
from OPM in the amount of $11,447.84.
…
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 RulingsNov 18, 2021
…luation for the AE silver coins. It valued the 2015 AE gold coins as of Decem ber 31, 2015, at $347,680 and valued
the 2015 and 2016 AE gold coins as of Decem ber 31, 2016, at $381,022.
Kingdom Trust required Mrs. McNulty to provide a yearend valuation of her
IRA’s assets. She com pleted a valuation form that she subm …
IRCCourt RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
IRCCourt RulingsMay 19, 2011
… "Management Fee" . The amounts were
as follows:"
Date Amount
Sept. 30, 2002 $600,000
Oct. 31, 2002 680,000
Nov. 30, 2002 995,000
Dec. 31, 2002 700,000
Total 2,975,000
Weekend Warrior paid Leading Edge as follows:
Date Amount
Dec. 20, 2002 $600,000
Dec. 27, 2002 700,000
Dec. 30, 2002 680,000
Dec. 31, 2002 995,000
Total…
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
IRCCourt RulingsFeb 2, 2022
…,887,918. In the notice of deficiency, respondent did not make a separate negative adjustment of $8,680,625 to reverse petitioner’s reported Schedule E passthrough
income from Morley of $8,680,625. Rather, respondent adjusted Mr. Larson’s pro rata
9
[* 9 ] determined that all or part s of Mr. Larson’s underpayments of …
IRCCourt RulingsMar 27, 1989related by meaning
983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary IRCProposed Rules (FR)Proposed Aug 22, 2011
…timate a one-time administrative cost of about $36,000,000 across the industry and a total of about 680,000 burden hours to prepare for the provisions of these proposed regulations. This calculation is made assuming issuers and TPAs will need to implement two principal tasks: (1) Develop teams to analyze current workfl…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
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for 1982 and that the related notice …
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCRegulationsJul 26, 2016
…cing 12 full months after his annuity starting date, the amount of the expected return would be $16,680 ($1,200 × 13.9 [14.4−0.5]).
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …