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Go to T.C. Summary Op. 2017-57 (not yet in the library — opens the official source)
75 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
  2. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    T.C. Summary Opinion 2019-26 PA UNITED STATES TAX COURT PASCAL NSAME AND LAMIAA MSALKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11462-15S. Filed September 23, 2019. Pascal Nsame and Lamiaa Msalka, pro sese. Timothy B. Heavner and Mary Ann Waters, for respondent. SUMMARY OPINION COLVIN, Ju…
  3. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  4. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    …nse of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burden of proving that there is no genuine issue…
  5. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    …rences are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. We must decide whether petitioner's contribution to its trust created as part of its voluntary employees' beneficiary association (VEBA) plan for the 1986 taxable year is deductible. Specifically, we mu…
  6. Notice 2017-69 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2017 used under § 417(e)(3)(D), the…
    IRCNoticesNov 27, 2017
    39 I.R.B. 408, Notice 2016–64, 2016–40 I.R.B. 429, and Notice 2017–50, 2017–41 I.R.B. 280, respectively. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for November 2017 without adjustment for the 25-year average segment rate limits are as follows: Adjus…
  7. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ities. Classification of the transaction as a prohibited transaction under section 408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is subject to a 10-percent additional tax. See secs. 72(t), 408(e) (2) (]B). In cases where the Service att…
  8. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    cipates in a reportable transaction and to each amended return that reflects that participation and send a copy of the disclosure statement to the IRS Office of Tax Shelter Analysis). Petitioners do not argue in their brief that the amended return was a "qualified amended return" within the meaning of sec. 1.6664-2(c)(…
  9. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    …scribed any expenditure that would qualify for a 2013 deduction or credit. In opposing a motion for summary judgment, the nonmovant may not rest upon the mere allegations or denials in his pleadings but instead must set forth specific facts showing that there is a genuine dispute for trial. Rule 121(d); see Sundstrand …
  10. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  11. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021related by meaning
    … in so concluding. See Pough v. Commissioner , 135 T.C. 344, 352 (2010). Considering the foregoing, summary judgment for respondent is appropriate in this matter . We have considered all of the arguments that the parties made , and to the extent they are not addressed herein, we consider them to be moot, irrelevant, or…
  12. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    bed in section 72(t) in respect of Mr. Merrell's IRA distribution is sustained. As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case. We have considered similar claims in the past and have observed that there is no -8au…
  13. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    we conclude that petitioner did not substantially prevail with respect to the most significant issue, we need not address whether respondent's - 13 - position was substantially justified. Accordingly, we will deny petitioner's motion. We have considered the remaining arguments of both parties for results contrary to th…
  14. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  15. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    …his discretion when he sustained the proposed levy action. The Court denied respondent's motion for summary judgment on the issues regarding petitioner's underlying liability. The Court held that petitioner properly challenged her underlying liability during her initial CDP hearing and in her petition. McCree v. Commis…
  16. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006related by meaning
    hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan. ADMINISTRATIVE Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
  17. Notice 2017-39 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2017 used under § 417(e)(3)(D), the 24-…
    IRCNoticesJul 31, 2017
    EMPLOYEE PLANS Notice 2017–39 Notice 2017–39 This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2017 used under § 417(e)(3)(D), the 24-month average segment rates applicable for July 2017, and the 30-year Treasury rates. These rates reflect the applic…
  18. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  19. Notice 2016-50 — This notice provides updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Internal Revenue Code (Code) and …
    IRCNoticesSep 19, 2016
    …e)(3) for distributions with annuity starting dates occurring during stability periods beginning in 2017 are set forth in the appendix to this notice in the column labeled “Unisex.” These tables were derived from the tables used for § 430(h)(3)(A) following the procedures set forth in Rev. Rul. 2007–67. Drafting Inform…
  20. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    …situation. Only Congress can change the statute. Accordingly, we will grant respondent's motion for summary judgment. To reflect the foregoing, An appropriate order and decision will be entered. 2Petitioner states: "I don't understand all the laws of government but one thing I do understand and can't believe is that th…