IRCCourt RulingsFeb 22, 1999related by meaning
lating to petitioners' loan,
10.5 percent is the fair market interest rate.
V. Addition to Tax
Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to
file Form 5330 for each taxable year, or portion thereof, in the
taxable period. Sec. 6011; sec. 54.6011-1(…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsJun 14, 2012related by meaning
ed work in her capacity as Yolo's employee or officer. Consistent with
our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties
A. s Burden of Proof
Respondent bears the burden of production with regard to the section
6651(a)(1) and (2) additions to tax and the …
IRCPrivate Letter RulingsDec 2, 2005related by meaning
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IRCCourt RulingsJun 11, 1996related by meaning
rary purpose has been shown here.
Because we are satisfied that our analysis of section
4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain
respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A.
- 11…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
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for 1982 and that the related notice …
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
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5
See also …
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsMar 5, 1987related by meaning
rmed in the employ of the United States further requires that the service be covered by a retirement system established by a law of the United States. We note that amendments made to the employment tax provisions subsequent to the years in issue have been interpreted in a manner inconsistent with our holding. See sec. …
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCCourt RulingsApr 10, 2018related by meaning
JRN
T.C. Memo. 2018-49
UNITED STATES TAX COURT
STACEY S. MARKS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18520-16. Filed April 10, 2018.
Ray C. Mayo, Jr., for petitioner.
Donielle A. Hubbard, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge: Respondent mailed petition…
IRCCourt RulingsOct 25, 1961related by meaning
ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
IRCCourt RulingsJul 26, 1989related by meaning
June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986).
The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…