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84 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    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…
  2. 73 T.C. 40 — La Fargue v. Commissioner
    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 …
  3. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  4. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    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…
  5. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    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…
  6. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    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…
  7. T.C. Memo. 1996-240 — Richard L. & Betty L. Seltzer v. Commissioner
    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. …
  8. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    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…
  9. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    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 …
  10. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    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…
  11. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    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…
  12. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    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…
  13. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    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…
  14. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    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 …
  15. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    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…
  16. 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…
  17. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 - 7 - for 1982 and that the related notice …
  18. 58 T.C. 115 — Doing v. Commissioner
    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…
  19. Treas. Reg. § 1.72-5(a)(2)(i) — Expected return.
    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]).
  20. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    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 — …