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93 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 58 T.C. 241 — Estate of Kleemeier v. Commissioner
    IRCCourt RulingsMay 8, 1972
    …annuity were as follows: Percent Northwestern University_ $337. 56 3. 10 Washington. University- 3, 806. 09 34. 93 Robert W. Kleemeier_ 6, 753. 16 61. 97 Total_ 10, 896. 81 100. 00 Robert and Washington University each contributed to the premium cost of the CREF annuity. The contribution of each, the percentage contrib…
  2. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  3. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    … 65 19.5 6.97% $5,897.88 66 20.5 6.90% 5,524.69 67 21.5 6.84% 5,164.63 68 and over Varies Varies 50,806.92 Total 67,394.12 (iii) Applying the 5% probability of withdrawal, the portion of the funding target for the 2009 plan year attributable to Participant E's assumed withdrawal at age 50 is $3,369.71 ($67,394.12 × 5%)…
  4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  5. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    GOFFE, Judge: The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    … with significant alterations, was placed in to section 45 of the Revenue Act of 1928, 45 St at. at 806. The other consolidated-return provisions of the Revenue Act of 1926 were placed into sections 141 and 142 of the Revenue Act of 1928, 54 Stat. at 831- 832. See G.D. Searle & Co. v. Commissioner , 88 T.C. at 356. 41 …
  7. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …dence.4 The Court need not and does not decide whether the Handbook is admissible under rule 807 or 806 of the Federal Rules of Evidence. Because the Court finds for respondent without it, the Court need not consider the Handbook in reaching a decision.5 FINDINGS OF FACT Some of the facts have been stipulated and are s…
  8. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …c, Inc . , 758 F . Supp . 543, 544, 551 (D .S .D . 1991) ; Deppisch v . United States , 227 Bankr . 806, 808-09 (Bankr . S .D . Ohio 1998) . This gives the IRS the power to seize taxpayers' property held in an IRA . See secs . 6331-6334 ; Kane v . Capital Guardian Trust Co . , 145 F .3d 1218, 1223 (10th Cir . 1998) (ri…
  9. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    notice of deficiency for 2000. Respondent assessed petitioners’ 2000 tax on the basis of the 2000 return. Petitioners raised the issue of their - 6 - underlying liability for 2000 in their hearing request, at the hearing, and in the petition. Accordingly, petitioners’ underlying liability is properly before the Court,…
  10. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …t of $78. As a result of these adjustments, respondent increased petitioner's taxable income by $17,806. Respondent disallowed petitioner's deduction for an IRA contribution in full. In addition, respondent determined that petitioner was liable for an accuracy-related penalty of $534 pursuant to section 6662(a) for neg…
  11. 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…
  12. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
  13. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    …last known address, actual receipt of the notice is not required. Y usko v. C ommissioner , 89 T.C. 806, 810 (1987); Frieling v. Commissione r
  14. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …ctually commenced. - 18 - [*18] See McKelvey v. Commissioner, T.C. Memo. 2002-63, afCd, 76 F. App'x 806 (9th Cir. 2003). "Until that time, expenses related to that activity are not 'ordinary and necessary' expenses currently deductible under section 162 (nor are
  15. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  16. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …al service income within the meaning of section 1348. See Kennedy v. Commissioner, 72 T.C. 793, 805-806 (1979).
  17. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008
    … could have been devoted to resolving bona fide claims of other taxpayers . See Cook v . Spillman , 806 F .2d 948 (9th Cir . 1986) . Petitioner's insistence on making frivolous tax-defier arguments indicates an unwillingness to respect the tax laws of the United States . Accordingly, we shall require petitioner to pay …
  18. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
  19. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …ely on ignorance of the law for relief from liability. Mitchell v. Commissioner , 292 F.3d 800, 803-806 (D.C. Cir. 2002), affg. T.C. Memo. 2000-332. Regardless of whether the taxpayer “possesses knowledge of the tax consequences of the item at issue, * * *[he] is considered as a matter of law to have reason to know of …
  20. 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…