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89 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …ributions of $372,850, reflecting the distribution from Plan 15104, 'but they determined that only $192,850 was taxable. After including interest income, dividend income, other income, and a capital loss of $3,000, petitioners reported adjusted gross income of $1,402,076. Petitioners' reported adjusted gross income did…
  3. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …,500 $275,000 $488,732 $275,000 $102,482 2005 19,925 167,964 254,704 167,964 32,515 2006 19,268 201,192 427,696 201,192 107,468 2007 19,253 221,664 422,716 221,664 91,573 And here's the big picture of BAI's original corporate returns for the years at issue: Year Total income Total deductions Taxable income 2003 $1,643,…
  4. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
  5. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  6. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  7. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  8. 76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner
    IRCCourt RulingsMar 17, 1981related by meaning
    implement the congressional mandate in some reasonable manner.’ ” (Citations omitted.) Commissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congr…
  9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005
    …ent is a neutral factor in determining whether TLC is the employer of each driver-employee." Id. at 192-193. That TLC may have paid TLC's payroll obligation with moneys that it received from its trucking company clients did not evidence to the Court in Transport Labor I that TLC was or was not the employer of each driv…
  10. 89 T.C. 939; 89 T.C. No. 65 — Estate of Neisen v. Commissioner
    IRCCourt RulingsOct 28, 1987related by meaning
    1954 as amended and in effect at the time of decedent's death, and all rules referred to are rules of the Tax Court Rules of Practice and Procedure.↩ 2. The House committee report contains similar language. See H. Rept. 97-201 (1981), 1981-2 C.B. 352↩, 379-380. See also Staff of Joint Comm. on Taxation, General Explana…
  11. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971
    … Tool & Machine Corporation, 27 T.C. 372 (1956); 555, Inc., 15 T.C. 671 (1950), affirmed per curiam 192 F. 2d 575 (C.A. 8, 1951). For purposes of determining whether contributions are deductible, it has been held that a trust exists when, and only when, the trust has a res. West Virginia Steel Corporation, 34 T.C. 851 …
  12. 34 T.C. 73 — Zeltzerman v. Commissioner
    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…
  13. 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…
  14. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    was made (1978), and for the subsequent years as to which determinations have been made as to Cass (1979), Lueckel (1979), and Strong (1979 and 1980). We have had occasion to consider the effect of a taxpayer’s purpose and intent in making the excess contributions. We concluded that: "Willfulness is not an element in i…
  15. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    rectly involved in such ruling. * * *” See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
  16. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …2,907 Business Operations Specialist 150 74.00 11,100 Lawyer 2 138.68 277 Chief Executive Officer 1 192.44 192 Total per respondent 2,508 221,029 Table 3B—Total High-End Estimated One-Time Cost and Hour Burden for Internet-Based Self-Service Tool for All Health Insurance Issuers and TPAs Number of respondents Number of…
  17. 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…
  18. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981
    …pt. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 341; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80,191-192. To provide for judicial review of respondent’s determination regarding a retirement plan before a notice of deficiency is issued, Congress enacted section 7476. However, the procedure provided therein is clearly an …
  19. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
  20. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …3 Areas in which determination letters will not be issued 191 .04 Determination letter applications 192 .05 Review of determination letters 192 SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 193 .01 Scope of this section 193 .02 Scope of determination letters 193 .03 Design-based safe harbor 193 .04 Go…