IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsApr 2, 2020
….................. 118 X. Period 15: July 27, 2009, through August 9, 2010. . . . . . . . . . . . . 119
1. Introduction...................................... 119
2. Events .......................................... 120
3. Analysis and holding............................... 121
Y. Intermediary period: August 10 through …
Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu… IRCRevenue RulingsDec 8, 2003related by meaning
INCOME TAX
Rev. Rul. 2003-122 Rev. Rul. 2003-122
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003.
T.D. 9095 T.D. 9095
REG-136890-02
Final, temporar…
IRCCourt RulingsSep 24, 2002
119 T.C. No. 6
UNITED STATES TAX COURT
ROBERT ANCIRA, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 425-01. Filed September 24, 2002.
P had a self-directed IRA account of which C was the
custodian. P requested that C purchase common stock in X
for the IRA. Although the investment in X stock was…
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…
IRCCourt RulingsNov 18, 2021
…887 F.3d 511, 523 (1st Cir.
2018), rev’g Sum m a Holdings, Inc. v. Com m issioner, T.C. Mem o. 2015-119; see
also Sum m a Holdings, Inc. v. Com m issioner, 848 F.3d 779, 785 (6th Cir. 2017),
rev’g T.C. Mem o. 2015-119. Benenson involved whether the Roth IRA’s receipt
of DISC dividends was an excessive contribution in v…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…9),
https://www.gao.gov/assets/gao-09-503t.pdf.
Back to Citation
373.
GAO Publication No. GAO-11-119,
401(K) Plans: Improved Regulation Could Better Protect Participants from Conflicts of Interest,
(2011),
http://www.gao.gov/products/GAO-11-119.
Back to Citation
374.
IRS,
SOI Tax Stats—Accumulation and Distributi…
IRCCourt RulingsFeb 24, 2016
…eld that this principle may apply in the case of a
taxpayer and an IRA, see Ancira v. Commissioner, 119 T.C. 135, 138 (2002); and
the IRS so acknowledges.5 The question at issue here is whether, in the wire
5As the Commissioner states in his supplemental opposition (at 7-8) to the
motion for summary judgment, "if Merri…
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…
IRCCourt RulingsDec 11, 2003
… pursued on brief, we may conclude that it has
been abandoned. See Clajon Gas Co. v. Commissioner
, 119 T.C.
197, 213 n.17 (2002); Davis v. Commissioner
, 119 T.C. 1 n.1
(2002); Nicklaus v. Commissioner
, 117 T.C. 117, 120 n.4 (2001);
Rybak v. Commissioner
, 91 T.C. 524, 566 n.19 (1988).
C. Sale of the IBM Stock--Alleg…
IRCCourt RulingsJun 11, 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. 1996-263
UNITED STATES TAX COURT
RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v
.
COMMISSI…
IRCCourt RulingsNov 4, 1998
…presentatives, and added the
language of S. 4, as amended, as an amendment at the end of H.R.
4200. 119 Cong. Reg. 30416 (1973). The Senate then passed H.R.
4200, as thus amended. 119 Cong. Rec. 30428 (1973).
As a result of the foregoing, the language of H.R. 4200 as
amended and passed by the Senate, insofar as it rela…
IRCCourt RulingsMay 19, 2011related by meaning
…al fact and that a decision may be rendered as a
matter of law. Rule 121(b); Craiq v. Commissioner, 119 T.C. 252,
-6259-260 (2002). As the moving party, respondent bears the burden
of proving that no genuine issue exists as to any material fact
and that he is entitled to judgment as a matter of law. See
Naftel v. Commi…
85 FR 72472 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions IRCFinal Rules (FR)Nov 12, 2020
…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 lifetime distributions to an employee in situations in whic…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
84 FR 60812 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions IRCProposed Rules (FR)Proposed Nov 8, 2019
…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.
Table 2 to paragraph (c), referred to as the Uniform Lifetime Table, sets forth the distribution period that applies for lifetime distributions to an employee in situations i…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…ry, and OPM share jurisdiction, HHS will account for 45 percent of the burden, or approximately, 95,119 hours at an equivalent cost of $9,299,924 and a cost burden of $216,582. DOL and the Department of the Treasury will each account for 25 percent of the burden, or approximately 52,844 hours at an equivalent cost of $…
IRCCourt RulingsMay 12, 1971
… U.S. 406, 413-414; Nuckolls v. United States, 76 F. 2d 357, 359 (C.A. 10) ; Everett Pozzi, 49 T.C. 119, 126; Lewis M. Ludlow, 36 T.C. 102, 107-108; Thomas F. Prendergast, Executor, 22 B.T.A. 1259, 1262. The effect of reporting sales proceeds under the installment method is thus deferral or postponement of much of the …
IRCCourt RulingsOct 10, 2018related by meaning
t was not a payment. The levy proceeds were an involuntary payment, and therefore
R did not abuse his discretion in applying the levy proceeds against Ps' 1995 income tax liability.
Hel_d, further, R's determination to deny Ps' installment
agreement proposal was not an abuse of discretion.
Juan F. Vasquez, Jr., and Ren…