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 RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsSep 3, 1998related by meaning
in participant's compensation,
effective for years beginning after Dec. 31, 1997. This
amendment does not apply to the instant case. We note, however, that the legislative history makes clear that Congress considered
the provisions of the then-existing law as requiring the result
reached herein and specifically intende…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
IRCCourt RulingsSep 25, 2019related by meaning
w that there is a
genuine dispute for trial that he had reasonable cause for not paying the unpaid tax
on the 2013 return made for him by RA Landadio. C. Summary Judgment
Rule 121(b) provides that, in the absence of a genuine dispute as to any
material fact, and if a decision may be rendered as a matter of law, we must…
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))…
Notice 2024-86 — Extension of Certain Timeframes for Employee Benefit Plans, Participants, Beneficiaries, Qualified Beneficiaries, and Claimants Affected by Hurricane Helene, T… IRCNoticesDec 23, 2024
…which individuals may file a benefit claim under the plan’s claims procedure pursuant to 45 CFR 147.136(b) (incorporating 29 CFR 2560.503–1); (6) the date within which claimants may file an appeal of an adverse benefit determination under the plan’s claims procedure pursuant to 45 CFR 147.136(b) (incorporating 29 CFR 2…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
e distribution.
Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
IRCRegulationsSep 9, 2016
…,358 are payable annually on January 1 instead of July 1.(iv) A new shortfall amortization base of $136,953 is established effective January 1, 2017 equal to the difference between the funding shortfall of $400,000 and the outstanding balance of the shortfall amortization base established as of July 1, 2016 ($263,047).…
80 FR 54374 — Determination of Minimum Required Pension Contributions IRCFinal Rules (FR)Sep 9, 2015
…358 are payable annually on January 1 instead of July 1.
(iv) A new shortfall amortization base of $136,953 is established effective January 1, 2017 equal to the difference between the funding shortfall of $400,000 and the outstanding balance of the shortfall amortization base established as of July 1, 2016 ($263,047).…
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont… IRCTreasury DecisionsSep 28, 2015
…358 are payable annually on January 1 instead of July 1.
(iv) A new shortfall amortization base of $136,953 is established effective January 1, 2017 equal to the difference between the funding shortfall of $400,000 and the outstanding balance of the shortfall amortization base established as of July 1, 2016 ($263,047).…
IRCCourt RulingsJun 1, 1987related by meaning
transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein,
Decision will be entered for the respondent.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
IRCCourt RulingsAug 10, 2015
… have been that all of
petitioner's deductions should be disallowed.
- 11 -
Dagres v. Commissioner, 136 T.C. 263, 277-278 (2011); see also Papineau v.
Commissioner, 28 T.C. 54, 57 (1957). New matter includes a new theory that
"'alters the original deficiency or requires the presentation of different evidence.'"
Dagres …
IRCRegulationsMay 18, 2016
…uals $164,000; (2) two percent of $1,400,000 equals $28,000; and (3) $164,000 minus $28,000 equals $136,000. Thus, because $136,000 exceeds $100,000, the minimum net worth necessary for Trustee X to accept new accounts for 1996 is $136,000.(d) For 1996, the amount determined under § 1.408-2(e)(5)(ii)(C) for Trustee X i…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
ces, and,
as passed through to him by the corporation, it became the basis
for a deduction by the corporation under section 162(a)(1)
4
as "a
- 10 -
4 (...continued)
deduction all the ordinary and necessary
expenses paid or incurred during the taxable
year in carrying on any trade or business,
including--
(1) a reasona…
IRCPrivate Letter RulingsMar 10, 2006related by meaning
ration of the taxing statutes. If a ruling is
revoked or modified, the revocation or modification applies to all open years under the
TAM-134113-05
15 statutes, unless the Commissioner or his delegate exercises the discretionary authority
under § 7805(b) to limit the retroactive effect of the revocation or modification…
IRCCourt RulingsOct 8, 2003related by meaning
f proof in this case
is affected by the fact that we carefully scrutinize transactions
between related parties, Maxwell v. Commissioner
, 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner
, 49 T.C.
649, 656 (1968), remanded pursuant to stipulation of the parties
406 F.2d 290 (6th Cir. 1969), and that…