IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCCourt RulingsOct 10, 2018
… agreements lies within the discretion of the
Commissioner. Thompson v. Commissioner, 140 T.C. 173, 179 (2013); sec.
301.6159-1(a), (c)(1)(i), Proced. & Admin. Regs. The Court does not make an
independent determination of what would be an acceptable collection alternative.
Thompson v. Commissioner, 140 T.C. at 179. If …
IRCCourt RulingsOct 1, 2025
… independent review of what would be an
acceptable OIC. See Thompson v. Commissioner, 140 T.C. 173, 179
(2013); Murphy , 125 T.C. at 320; see also Randall v. Commissioner, T .C.
Memo . 2018- 123, at *9. “If the settlement officer followed all statutory
and administrative guidelines and provided a reasoned, balanced
dec…
IRCCourt RulingsFeb 9, 1998related by meaning
ts to be
frivolous.
OPINION
At trial, petitioner conceded that if the Court finds him
subject to Federal income tax, he had adjusted gross income from his veterinary practice of $65,000 in each of the years in issue.
Petitioner also conceded that he received interest and dividend
income and short-term capital gain in 1…
IRCCourt RulingsOct 16, 2017related by meaning
ord contained no loan documents or other evidence showing that the
distribution was evidenced by a legally enforceable agreement).
III. Additional Tax Section 72(t)(1) imposes a 10% additional tax on early distributions from
qualified retirement plans. Section 72(t)(2), however, sets forth specific
exceptions to the ge…
IRCCourt RulingsMay 28, 1962related by meaning
ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…mbined Oral Contraceptive Use Among Women With Hypertension: A Systematic Review,” 73 Contraception 179, 179-188 (2006); L.A. Gillum et al., “Ischemic stroke risk with oral contraceptives: A meta analysis,” 284
JAMA
72, 72-78 (2000), available at
https://www.ncbi.nlm.nih.gov/pubmed/10872016;
and Robert A. Hatcher et …
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 …
IRCCourt RulingsNov 10, 1998related by meaning
1
All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
T.C. Memo. 1998-399
UNITED STATES TAX COURT
RONNY H. AND CHARLOTTE A. SCHMALZER, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21…
IRCCourt RulingsMar 5, 1987related by meaning
ies thereby created.
We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…8]
Ohio brought a lawsuit against Centene, who ultimately agreed to pay $88.3 million to the State [179]
and also switched to a pass-through pricing contract, which increased payments to pharmacists by 5.74 percent, though this was significantly less than the “spread” of 31.4 percent on generic drug claims from April 2…
IRCCourt RulingsDec 16, 2015related by meaning
treatment, but that caveat appears to be inapplicable boilerplate as
the amount of the penalty, $28,483, is exactly 20% of the notice's determined tax deficiency of $142,416.
B. Applicable Law
Section 6662(a) and (b)(1)-(3) provides for an accuracy-related penalty (the
penalty) in the amount of20% of the portion of any…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…p health plans.[177]
Of these plans, approximately 35.7 percent [178]
(or 32,400) are self-insured,[179]
and 64.3 percent (or 58,400) are fully funded.[180]
2. Participants, Beneficiaries, and Enrollees
The Departments estimate that there are 135.5 million participants in ERISA-covered group health plans, of which 78.9…
IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
IRCCourt RulingsMay 17, 1973
…rt of our characterization of the legislative history of the term “earned income,” see H. Rept. No. 179, 68th Cong., 1st Sess., pp. 5-6 (1924) ; S. Rept. No. 398, 68th Cong., 1st Sess., pp. 7 — 8 (1924) (wherein the distinction is drawn between income derived from capital and income that is the result of personal effor…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsSep 11, 1972related by meaning
tation of that section. Petitioners contend that Eev. Eul. 69-544 is at variance with the plain wording of section 1.72-16 (b) (6) of the regulations. In Raymond J. Moore, 45 B.T.A. 1073 (1941), we held that the portion of the premiums paid by a qualified pension trust for the benefit of employees for an annuity contra…
IRCCourt RulingsSep 29, 2022related by meaning
ith section
6751(b) (1). That section provides: “ No penalty under this title shall be
assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the
9
The SFRs comprise Form s 4549, 886– A, and 13496. That combination of
documents is sufficient to co…
Notice 2010-83 — Funding relief for multiemployer defined benefit plans under PRA 2010. This notice provides guidance in the form of questions and answers for sponsors of multi… IRCNoticesDec 20, 2010
…the expected rate of return during 2008, the market value of assets as of January 1, 2010, will be $179.65 [($161.50 * 1.10) + $12 - $10] and the difference between actual and expected returns for 2009 will be $4.84.
Under the asset valuation method for the plan, the actuarial value of assets on January 1, 2010, prior …
IRCCourt RulingsJan 2, 2020related by meaning
relevant times, and all Rule references are to
the Tax Court Rules of Practice and Procedure. All monetary amounts are
rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross
income rental income of $4,920 they received in 2007.
- 3 -
[*3] to deduct a net operating loss (…