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  1. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …00 36,975,000 617,750 18,285,400 617,750 18,285,400 Uniform Glossary 1,102,000 1,102,000 18,367 543,653 18,367 543,653 Notice of Modification 1,160,000 719,200 11,987 354,805 11,987 354,805 Total 62,909,328 39,059,864 652,498 19,313,933 652,498 19,313,933 The Departments note that persons are not required to respond to…
  2. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  3. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    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…
  4. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008★ strong match
    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…
  5. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  6. Treas. Reg. § 1.401(a)(9)-6(m)(4)(ii)(A) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    …$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 20,257 326,859 Table 5 to Paragraph (m)(4)(ii)(A) Year Survivorshipto startof year Interestdiscount…
  7. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  8. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005
    …gton University, and Evergreen State College. In 2001, Central Washington University contributed $4,653.22 on petitioner's behalf to a. retirement plan in the
  9. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    023.94 81,023.94 81,023.94 81,023.94 64,819.15 For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…
  10. PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.)
    IRCPrivate Letter RulingsJun 25, 1999
    …m the corporation' s ordinary assets in order to fund the plan. Dependahl v. Falstaff Brewing Co. , 653 F. 2d 1208, 1214 (8th Cir. 1981), cert. denied 454 U.S. 968 (1981). Thus, whether there has been a transfe r of property for the performance of service within the meaning of §83, or a person has incurred an economic …
  11. 35 T.C. 1217 — Searl v. Commissioner
    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…
  12. T.C. Memo. 2001-118 — Roydell Campbell v. Commissioner
    IRCCourt RulingsMay 17, 2001
    …l income tax return, petitioner itemized his deductions on Schedule A and claimed a deduction of $4,653.55 for State and local taxes. Petitioner was entitled to a refund
  13. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    T .C . Memo . 2007-292 UNITED STATES TAX COUR T HUBERT JOUBERT, Petitioner V . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 8769-06 . Filed September 24, 2007 . P failed to file a Federal income tax return for 2002 . R determined a deficiency and asserted in the notic e deficiency, the answer, and the pret…
  14. T.C. Memo. 1998-52 — Robert E. Dunham v. Commissioner
    IRCCourt RulingsFeb 9, 1998
    …onsidered in imposing the fraud penalty under section 6663. Clayton v. Commissioner , 102 T.C. 632, 653 (1994). Fraud is an intentional wrongdoing designed to evade tax known or believed to be owing. Edelson v. Commissioner , 829 F.2d 828, 833 (9th Cir. 1987), affg. T.C. Memo. 1986-223; Bradford v. Commissioner , 796 F…
  15. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    o be treated as an amount received as a loan on the date of such renegotiation, extension, renewal, or revision. TEFRA, sec. 236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2) if it (1) is in an amount not exceeding a prescribed ceiling that in no event may be more than $50,000, …
  16. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    tal stipulation of facts are incorporated herein by this reference and found accordingly. Petitioner, an accrual basis taxpayer, is a corporation with over 1,300 employees that, at the time of the filing of the petition, had its principal place of business in Baltimore, Maryland. It filed timely Federal income tax retu…
  17. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014★ strong match
    … need to look to policy considerations), aff'a 130 T.C. 34 (2008); Easson v. Commissioner, 294 F.2d 653, 657 (9th Cir. 1961) (reversing the Tax Court for "failing to adhere to the unambiguous language contained in the statutes in question"), rev'g 33 T.C. 963 (1960); Hawkins v. Commissioner, 86 F.3d 982, 989 (10th Cir.…
  18. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012★ strong match
    …hat petitioners be relieved of them. See Mathia v. Commissioner, T.C. Memo. 2007-4, 93 T.C.M. (CCH) 653, 656 (2007) (unilateral mistake was not grounds for relieving Commissioner of disputed stipulations). Justice does not favor relieving petitioners of the stipulations because even if petitioners were permitted to äha…
  19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  20. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …