IRCCourt RulingsJun 11, 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
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsFeb 20, 2003
…a deficiency in petitioner’s Federal
- 2 -
2
The notice of deficiency determined a deficiency of
$2,655 of which $124 represented tax on unreported interest
income, which petitioner concedes. Therefore, the amount of
deficiency at issue is $2,531.
income tax for the taxable year 1999 in the amount of $2,655.
After a co…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsMay 20, 1976related by meaning
proprietor.
The record discloses the following:
Direct Net profit corporate Deferred Total Year from profession compensation compensation compensation 1964_ $47,620 $47,620.00
1965_ 38,039 38,039.00
1966_ 53,246 53,246.00
1967_ 62,450 62,450.00
1968_ 72,735 72,735.00
1969_ 75,702 75,702.00
1970:
1/1 -11/23_ 81,473
11/2…
78 FR 72018 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 2, 2013
…ter than—
From—
To—
2015
614
614
2,594
2,594
2016
627
627
2,651
2,651
2017
641
641
2,710
2,710
2018
655
655
2,769
2,769
2019
670
670
2,830
2,830
2020
685
685
2,893
2,893
2021
700
700
2,956
2,956
2022
715
715
3,021
3,021
2023
731
731
3,088
3,088
2024 or later
747
747
3,156
3,156
1
Table II-A.
2
Table II-B.
3
Table II-C.…
ERISACourt RulingsAug 10, 2026
…not encompass the stock appraisal reports
and trustee meeting minutes at issue in that case. Id. at 655. But it did encompass funding
and investment policies because they “set forth [] obligations to fund the [ plan ] and
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
ERISACourt RulingsAug 10, 2026
…not encompass the stock appraisal reports
and trustee meeting minutes at issue in that case. Id. at 655. But it did encompass funding
and investment policies because they “set forth [] obligations to fund the [ plan ] and
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
83 FR 63802 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 12, 2018
…um 3
if monthly benefit at URA is—
High 4
if
monthly
benefit at
URA is
greater than—
From—
To—
2020
655
655
2,767
2,767
2021
670
670
2,831
2,831
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
80 FR 74986 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2015
…ly benefit at URA is greater than—
From—
To—
2017
627
627
2,647
2,647
2018
640
640
2,705
2,705
2019
655
655
2,767
2,767
2020
670
670
2,831
2,831
2021
686
686
2,896
2,896
2022
701
701
2,962
2,962
2023
718
718
3,030
3,030
2024
734
734
3,100
3,100
2025
751
751
3,171
3,171
2026 or later
768
768
3,244
3,244
1
Table II-A.
2…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsJan 31, 2001
…-half (1/2) of
returned bail money.
- 15 -
(e) $1,000.00 – from the MacDill Credit Union;
and,
(f) $655.00 – cash from Husband.
It is unclear what the State Court meant by “the parties’
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…