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95 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2016-228 — Suzanne D. Oster Ozimkoski v. Commissioner
    IRCCourt RulingsDec 19, 2016
    …ed $75,000 or when the decedent has been deceased for more than two years. See Fla. Stat. Ann. sec. 735.201(2) (West 2010). ¹°It is not clear from the record whether petitioner's probate attorney (continued...) - 13 - [*13] The settlement agreement required payment of the $110,000 within 30 days after Wachovia unfroze …
  2. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    ualified retirement plan within the meaning of sec. 4974(c). In the light of our holding that the "additional tax" under sec. 72(t) is not a "penalty, addition to tax, or additional amount" under sec. 7491(c), we deem this issue conceded. - 11 - received the deemed distribution or that any other exception in section 72…
  3. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …ers reported adjusted gross income of $564,156, itemized deductions of $427,211, a total tax of $33,735, an overpayment of tax of $116,498. Petitioners requested a refund of $105,228 and that $11,270 be applied to their estimated tax for 2000. Petitioners' 1999 tax return did not include a Form 6251, Alternative Minimu…
  4. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    tions. Sec. 72(t)(3)(A). or after the death of the employee; (3) attributable to the employee's being disabled within the meaning of section 72(m)(7); (4) part of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the employee or joint lives (…
  5. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …89 1989 1,423,786 3462-92 MIT 86 1987 4,855,505 3551-92 MIT 83 1987 797,976 1988 360,236 1989 1,218,735 3221-93 W & A 1988 3,586,156 The cases in the foregoing dockets have been selected by the parties as test cases that will resolve common issues in more than 120 cases in a group identified by respondent as "Fred Brye…
  7. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    te minus amounts received before such date to the extent excludible from gross income. Sec. 72(e)(6). The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to him of income and as the parties have agreed is subject to the 10-percent premature distribution tax und…
  8. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  9. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    … as they are consistent with Rev. Rul. 2001-6, supra, see Smilev v. Citibank (S.D.), N.A., 517 U.S. 735, 744 n.3 (1996) ("Where * * * a court is addressing transactions that occurred at a time when there was no clear agency guidance, it would be absurd to ignore the agency's current authoritative pronouncement of what …
  10. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    y for purposes of applying such section. * * * Sec. 83(a) and (c)(1) states: SEC. 83. PROPERTY TRANSFERRED IN CONNECTION WITH PERFORMANCE OF SERVICES. (a) General Rule. — If, in connection with the performance of services, property is transferred to any person other than the person for whom such services are performed,…
  11. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
  12. 78 T.C. 395; 78 T.C. No. 27 — Sutherland v. Commissioner
    IRCCourt RulingsMar 9, 1982
    …lary level of demarcation. Compare Tamko Asphalt Products, Inc. of Kansas v. Commissioner, 658 F.2d 735 (10th Cir. 1981), affg. 71 T.C. 824 (1979).
  13. T.C. Summary Opinion 2004-1 — Lawrence K. Mudd v. Commissioner
    IRCCourt RulingsJan 8, 2004
    …), (e), Income Tax Regs. We conclude that petitioner made deductible charitable contributions of $3,735.64 during 1996. - 13 - Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155 .
  14. 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…
  15. 143 T.C. No. 21 — Key Lime Investments, Inc. v. Commissioner
    IRCCourt RulingsNov 26, 2014
    …inuing qualification of a retirement plan. See Tamko Asphalt Prods., Inc. v. Commissioner, 658 F.2d 735, 738-739 (10th Cir. 1981), affg. 71 T.C. 824 (1979); H. Rept. 93-807, at 108 (1974), 1974-3 C.B. (Supp.) 236, 343; S. Rept. 93-383, at 114 (1973), 1974-3 C.B. (Supp.) 80, 193; see also Wenzel v. Commissioner, * * * […
  16. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005related by meaning
    the deficiency in this case. With respect to petitioners' first contention, as noted earlier, section 72(t)(2) excepts from the additional tax certain categories of distributions. Petitioners agree that none of these categories apply to their fact situation. Instead, petitioners contend that, because of financial hards…
  17. 61 T.C. 605; 61 T.C. No. 65 — Estate of Silverman v. Commissioner
    IRCCourt RulingsFeb 4, 1974
    …ficiaries he designated. The United States Court of Appeals for the Seventh Circuit there stated (p.735) :
  18. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013
    …ficers: J. Lipsmeyer $981,728 $746,229 M. Lipsmeyer 215,000 198,000 Employees: D. Lipsmeyer 922,853 735,029 Stewart 287,528 287,429 Petitioner claimed deductions for the Business Property rent of $564,000 and $651,000 on the 2006 Form 1120 and 2007 Form 1120, respectively. On April 21, 2011, respondent sent to petition…
  19. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963related by meaning
    422, 441. Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
  20. T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen…
    IRCTreasury DecisionsFeb 26, 2007related by meaning
    tal wages. The regulations apply to all employers and others making supplemental wage payments to employees. Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…