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100 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Notice 2021-31 — This notice provides guidance on issues relating to the application of § 9501 of the American Rescue Plan Act of 2021 (the ARP), which provides temporary premi…
    IRCNoticesJun 7, 2021
    …d wages under § 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. 116-136, 134 Stat. 281 (March 27, 2020), as amended by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), which was enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L. 116-2…
  2. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respo…
  3. Notice 2020-51 — This notice provides guidance relating to the waiver in 2020 of required minimum distributions (RMDs) from certain retirement plans and IRAs due to the amendme…
    IRCNoticesJul 13, 2020
    … plans under section 2203 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub.L. 116-136, 134 Stat. 281 (2020). In particular, the notice: permits rollovers of waived required minimum distributions (RMDs) and certain related payments, including an extension of the 60-day rollover period for certain d…
  4. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    T.C. Memo. 1995-492 UNITED STATES TAX COURT GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7123-93. Filed October 11, 1995. Robert G. Cassilly , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Jud…
  5. T.C. Memo. 2016-228 — Suzanne D. Oster Ozimkoski v. Commissioner
    IRCCourt RulingsDec 19, 2016
    …e tax required to be shown on the tax return or $5,000. Sec. 6662(d)(1)(A); Higbee v. Commissioner, 116 T.C. at 448. As stated supra p. 17, under section 7491(c) the Commissioner bears the burden of production with regard to penalties. Higbee v. Commissioner, 116 T.C. at 446. Once the Commissioner has met the burden of…
  6. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012★ strong match
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  7. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    ethod is $116. The amount that would be paid under Medicare for the emergency service, excluding any copayment or coinsurance for the service, is $80. (ii) Conclusion. In this Example 5, the plan is responsible for paying $92.80, 80% of $116. The median amount among those agreed to for the emergency service is $115 and…
  8. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …ners' Federal income tax: - 2 - Year Deficiency Sec. 6662 Penalty 1990 $22,763 $4,553 1991 25,581 5,116 Unless stated otherwise, all section references are to the Internal Revenue Code as in effect during the years in issue. The issues remaining for decision are: (1) Whether loans that petitioner received from a qualif…
  9. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …rtion of an underpayment for which the taxpayer shows reasonable cause and good faith. See Higbee , 116 T.C. at 448. Reasonable cause is determined case by case, considering all pertinent facts and circumstances. Treas. Reg. § 1.6664- 4(b)(1). The inquiry focuses on whether the taxpayer exercised ordinary business care…
  10. 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 …
  11. Treas. Reg. § 1.401(a)(9)-9(d) — Life expectancy and distribution period tables.
    IRCRegulationsSep 17, 2024
    …3.1 3.1 3.0 3.0 2.9 114 3.6 3.5 3.3 3.2 3.1 3.0 3.0 2.9 2.9 115 3.6 3.4 3.3 3.2 3.1 3.0 2.9 2.9 2.9 116 3.5 3.3 3.2 3.1 3.0 2.9 2.8 2.8 2.8 117 3.4 3.3 3.1 3.0 2.9 2.8 2.7 2.7 2.7 118 3.3 3.1 3.0 2.8 2.7 2.6 2.6 2.5 2.5 119 3.1 2.9 2.8 2.6 2.5 2.4 2.4 2.3 2.3 120+ 3.0 2.8 2.6 2.5 2.3 2.2 2.1 2.1 2.1 Table 3 to Paragrap…
  12. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  13. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    t for payment of an assessed deficiency and the bank trustee paid the money directly to the IRS. Former section 72(m)(5) differed from current section 72(t), particularly in that the former did not include the list of specific exceptions to tax set forth in section 72(t)(2). Swihart v. Commissioner , T.C. Memo. 1998-40…
  14. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …ctive interest rate of 5.5% for 2009. Accordingly, the prefunding balance used for this purpose is $116,050 [($125,000 − $15,000 deemed reduction) × 1.055].(iii) The fair market value of plan assets used for the December 31, 2010, valuation is $883,950 ($1,000,000 − $116,050). Example 11.(i) The facts are the same as i…
  15. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
  16. Notice 2024-3 — 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans
    IRCNoticesJan 8, 2024
    …000 or 150% of the regular catch-up limit for 2025, indexed for inflation. 10. Section 415: Section 116 of the SECURE Act amends section 415(c) of the Code to treat difficulty of care payments that are excluded from gross income as compensation for determining retirement contribution limitations. Notice 2020-68 provide…
  17. PLR 202430007 — Employees of Businesses Under Common Control
    IRCPrivate Letter RulingsJul 26, 2024
    …in section 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub . L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020), as amended by section 206 of the Taxpayer Certainty and Disaster Tax Relief Act (Relief Act), which was e nacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L…
  18. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …ome forward with persuasive evidence that the penalt ies are inappropriate. See § 7491(c); Higbee , 116 T.C. at 446 – 47. Petitioners may meet their burden by proving that they acted with reasonable cause and in good faith with respect to the underpayment s . See § 6664(c)(1); see also Higbee , 116 T.C. at 447; Treas. …
  19. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  20. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    … 54 - evidence indicating that it is appropriate to impose the penalty. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his burden of production, however, the burden of proof remains with the taxpayer, including the burden of proving that the penalty is inappropriate because of reasona…