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79 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. IRCCourt RulingsAug 3, 1979related by meaning
    to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption. II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
  2. T.C. Memo. 2009-140 — James A. Haigh v. Commissioner
    IRCCourt RulingsJun 15, 2009
    … . Internal Revenue Service Restructuring and Reform Act of 1998,i1Pub . L . 105-206, sec . .3201 ; 112 Stat . 734 . Sec . 6015 applies to any liability for tax remaining unpaid as of July 22, 1998 . Id . .sec . 3201(g)(1), 112 Stat . 740 . - 29 - prevents that spouse from qualifying fo : Commissioner , 119 T .C . 306,…
  3. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017
    JRN T.C. Memo. 2017-112 UNITED STATES TAX COURT WHISTLEBLOWER 19860-15W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19860-15W. Filed June 13, 2017. Sealed,¹ for petitioner. Ashley M. Bender and Richard L. Hatfield, for respondent. MEMORANDUM OPINION KERRIGAN, Judge: This case is before the Co…
  4. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her authority that would distinguish the Martin cases from the issue presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA - 25 - [*25] distributions is substantial in relation to the weight of the authorities sup…
  5. 64 T.C. 331 — Aero Rental v. Commissioner
    IRCCourt RulingsMay 29, 1975
    112 (1973). As a result, it is customary for an employer to request a determination that the plan is qualified. See Rev. Proc. 72-6, 1972-1 C.B. 710. Frequently, there arise differences of opinion as to whether a proposed plan meets the qualification requirements. To secure a favorable determination, the employer may …
  6. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    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 - […
  7. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    … purposes of the sec. 6651(a) addition to tax, petitioners are entitled to take into account the $1,112.23 income tax withholding shown on petitioner-husband’s Form W-2 (sec. 6651(b)). Respondent apparently has not taken into account for this purpose the 1977 estimated tax payment of $316.42 shown on petitioner’s Form …
  8. 89 FR 104915 — Regulations Governing Practice Before the Internal Revenue Service
    IRCProposed Rules (FR)Proposed Dec 26, 2024
    Register ]. Par. 42. Sections 10.111 and 10.112 are added to read as follows: § 10.111 Establishment of advisory committees. (a) Advisory committees. To promote and maintain the public's confidence in tax advisors, the Internal Revenue Service is authorized to establish one or more advisory committees composed of at l…
  9. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  10. 85 FR 72472 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions
    IRCFinal Rules (FR)Nov 12, 2020
    …3.0 100 2.8 101 2.6 102 2.5 103 2.3 104 2.2 105 2.1 106 2.1 107 2.1 108 2.0 109 2.0 110 2.0 111 2.0 112 2.0 113 1.9 114 1.9 115 1.8 116 1.8 117 1.6 118 1.4 119 1.1 120+ 1.0 (c) Uniform Lifetime Table. The following table, referred to as the Uniform Lifetime Table, sets forth the distribution period that applies for lif…
  11. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    or 1993 and 1994, respectively, to be applied against the determined deficiencies. OPINION As an initial matter, petitioner moved during trial to have his case dismissed for lack of jurisdiction. He contends that the Court lacks jurisdiction to hear cases involving withholding taxes and that withholding taxes are in is…
  12. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …890 continues to read as follows: Authority: 5 U.S.C. 8913; Sec. 890.102 also issued under sections 11202(f), 11232(e), and 11246(b) of Pub. L. 105-33, 111 Stat. 251; Sec. 890.111 also issued under section 1622(b) of Pub. L. 104-106, 110 Stat. 521 (36 U.S.C. 5522); Sec. 890.112 also issued under section 1 of Pub. L. 11…
  13. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    alty equal to 20 percent of the portion of the underpayment of income tax that is attributable to negligence. Negligence includes the failure to - 7 - make a reasonable attempt to comply with the law and disregard of the rules and regulations includes any "careless, reckless, or intentional disregard." Sec. 6662(c). Wh…
  14. 89 FR 43636 — Abandoned Plan Regulations
    ERISAFinal Rules (FR)May 17, 2024
    … of clerical staff time with an associated cost burden of $14,171 (223 hours × $63.45 per hour) and 112 hours of an accountant's time with an associated cost burden of $13,049 (112 hours × $116.86 per hour).[65] These notices are sent by a method requiring acknowledgement of receipt. Therefore, mailing costs include $6…
  15. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    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.
  16. 88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCFinal Rules (FR)Dec 21, 2023
    9817. Back to Citation 13.  29 U.S.C. 1185f, et seq. Back to Citation 14.  42 U.S.C. 300gg-112, et seq. Back to Citation 15.  42 U.S.C. 300gg-131-139. Back to Citation 16.  86 FR 36872 (July 13, 2021). Back to Citation 17.  86 FR 55980 (October 7, 2021). Back to Citation 18.  87 FR 52618 (August 26, 2022). Back to Cita…
  17. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
  18. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    ax of $3,000.60 because she received.the distributions before she attained age 59-1/2 and the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v). Discussion Summary judgment is intended to.expedite litigation and avoid unnecessary and expensive trials and may be granted where the…
  19. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009related by meaning
    statutory provisions by numerous cases . On the record before us, we are satisfied that petitioners acted in good faith and with reasonable cause with respect to that portion of the underpayment relating to the 10percent additional tax under section 72(t) . Such was not the case with respect to the understatement relat…
  20. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…