IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
IRCCourt RulingsJul 25, 1974related by meaning
ew principal place of work.
Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217.
SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
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 …
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 RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsApr 18, 1960related by meaning
Section 403(a) of the Internal Revenue Code of 1954 is, in the main, a reenactment of section 22(b) (2) (B) of the Internal Revenue Code of 1939. The latter was enacted by section 162 of the Revenue Act of 1942, which also amended section 165 and section 23 (p) of the 1939 Code. The congressional committee reports deal…
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)…
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…
T.D. 9459 — Final regulations under sections 401(a)(9) and 403(b) of the Code permit a governmental plan to comply with the required minimum distribution rules by using a … IRCTreasury DecisionsOct 13, 2009related by meaning
cifications for Filing Forms 1098, 1099, 3921, 3922, 5498, 8935, and W-2G, Electronically, revised (7-2009).
Announcement 2009-73 Announcement 2009-73 This document contains corrections to final regulations (T.D. 9456, 2009-33 I.R.B. 188) providing guidance regarding the treatment of controlled services transactions un…
IRCCourt RulingsAug 8, 2019related by meaning
he foregoing principles in mind, we turn to section 72(t)(2)(F) and
begin with its title: "Distributions from certain plans for first home purchases." Although statutory titles and section headings do not define a statute's meaning
and are not generally relied on at the expense of the statutory text itself, such titles…
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
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsAug 3, 1979related by meaning
ty might be reduced. Thus far, it has been defeated by considerations of undue complexity and revenue effects exceeding half a billion dollars a year. Were we to declare section 219(b)(2) (or subparagraph (A)(i) thereof) unconstitutional, we would be faced with the same problems of line-drawing that have thus far defea…
IRCCourt RulingsMay 14, 2012related by meaning
etitioner does not cite any relevant law to establish her position. We
similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of
section 61, that all income is taxable unless explicitly excluded. See Baldwin v.
Commissi…
81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
the Department proposed to restrict relief to IRA fiduciaries with discretionary authority or control over the management of the IRA's assets (
i.e., investment managers) and to impose the exemption's protective conditions on investment management fiduciaries when they engage in transactions with IRAs. Finally, the De…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…