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88 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  2. 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…
  3. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  4. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  5. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …entatives. Air Ambulance. Data Collection and Transparency Needed to Enhance DOT Oversight. (GAO-17-637) available at: https://www.gao.gov/​assets/​gao-17-637.pdf. Back to Citation 125.  Consumer Union. Up in the Air: Inadequate Regulation for Emergency Air Ambulance Transportation. Health Policy Report, March 2017. Ba…
  6. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  7. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    8 years on June 10, 2016. That notice was issued timely because, as of 3 The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
  8. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959
    …otal After renegotiation Renegotiate Nonrene-gotiable Total Sales.. Net profit... Percentage.. $527,637 $150,991 28.61* i $16,490 $4,764 28.8 $544,127 $155,755 28.6 $432,637 $55, 991 12.9 $16,490 $4,764 28.8 $449,127 $60,755 13.5 1 Of this amount $16,054 represented sales of salted peanuts to the corporation and its su…
  9. Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”…
    IRCRevenue ProceduresOct 15, 2018
    …36 .02 Submission of model forms 636 .03 Mandatory submission process using the www.pay.gov website 637 .04 PDF file submission contents 637 .05 User fee due at the time of VCP submission using the www.pay.gov website 638 .06 Additional amount due for Group Submissions 638 .07 Additional amounts due for certain submiss…
  10. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …cket No. 5754-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $12,744 $637 $2,549 Howard S. Young & Elaine P. Young (the Youngs), docket No. 5755-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $14,008 --- $2,802 Bruce E. Traegde & Patricia Traegde (the Traegdes…
  11. REG-114726-04 — Proposed regulations under section 401(a) of the Code provide rules permitting distributions to be made from a pension plan under a phased retirement program a…
    IRCProposed Rules (FR)Proposed Nov 22, 2004
    …it as of July 1, 2009, as a single life annuity commencing at normal retirement age is equal to $30,637.50 per year ($95,000 times 1.5% times 21.5 years of service) and, after the offset for E’s phased retirement accrued benefit, E’s retirement benefit as a single life annuity commencing at normal retirement age is equ…
  12. 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…
  13. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …ommissioner, T.C. Memo. 2010-31, slip op. at 2 1 ( c it ing Stephenson , 79 T.C. at 1006) , aff’d , 637 F.3d 767 (7th Cir. 2011) ; see also Niedringhaus , 99 T.C. at 211 . Mr. Janangelo is a tax professional. He is a licensed attorney, a certified public accountant, and (for many years) an employee of the IRS. He posse…
  14. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    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…
  15. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    E. France from Jos. A. Bank Clothiers, Inc., and the parties stipulate that the correct amount for taxable year 2000 is $4,525. Based on this, we hold that petitioners’ taxable year 2000 wage income is to be reduced in the amount of $737. Issue 3. Taxable Year 1997 Respondent issued a notice of deficiency for taxable y…
  16. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …SHIP R EPRESENTATIVE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 637-23 . Filed July 15, 2026. ————— P is an LLC that is treated as a partnership for federal tax purposes. P is subject to the centralized partnership audit regime established by the Bipartisan Budget Act of 2015 (BBA), …
  17. Treas. Reg. § 1.72-7(e) — Adjustment in investment where a contract contains a refund feature.
    IRCRegulationsJul 26, 2016
    …portion of the investment in the contract adjusted for refund feature ($43,516 less $10,879.00) $32,637.00 Sum of A's and B's allocable portions of the investment in the contract after adjustment for the refund feature $66,414.00 Exclusion ratio for the contract as a whole (total adjusted investment in the contract, $6…
  18. 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…
  19. IRCRegulationsSep 9, 2016
    …Estimated base units* 110,000 110,000 110,000 19. Estimated unit charge (line 17 ÷ line 18) 1.576 1.637 1.667 20. Actual units during year* 105,000 110,000 105,000 21. Net shortfall charge for year (line 19 × line 20) 165,480 180,070 175,035 22. Shortfall (gain) loss (line 17−line 21) 7,884 (24) 8,329 The amounts in li…
  20. Treas. Reg. § 1.417(e)-1(d)(7)(v)(A) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …-sum payment of $42,129, Participant S receives a 100% joint and survivor annuity in the amount of $637.50 per month, which is determined by applying the plan's unreduced early retirement and actuarial equivalence factors to the remaining portion of the accrued benefit of $750 per month payable as a straight life annui…