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85 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    y, she has failed to establish that "she did not know, and had no reason to know, that there was [an] understatement" . Sec . 6015(b) (1) (C) . - 10 - The Court concludes that petitioner has failed to satisfy the requirements of section 6015(b)(1)(C)6 Therefore, petitioner does not qualify for relief from joint and sev…
  2. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    164 T.C. at 151. When applied to vacant land, the approach can be highly sensitive to assumptions, and unsupported projections have undermined income an alyses in many conservation easement cases. See, e.g., Savannah Shoals, T.C. Memo. 2024-35, at *36 (“Income valuation methods are not favored when valuing vacant land…
  3. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …nt value of a hypothetical limestone business conducted on the land. See Ranch Springs, 164 T.C. at 151– 53; Beaverdam Creek , T.C . Memo, 2025- 53, at *36. Even if we were to conclude that the highest and best use of the Property w as as a limestone mine, Mr. Catlett’s before value of $34,540,000 would fail because it…
  5. 29 C.F.R. § 2570.113 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  6. Treas. Reg. § 1.72-17(ii)(4) — Special rules applicable to owner-employees.
    IRCRegulationsJul 26, 2016
    …t regard to the distribution, he had a net operating loss and for which he is allowed under section 151 a deduction for one personal exemption. The portion of the distribution includible in B's gross income is $25,750. In addition, B had a net operating loss for 1972. The other 3 taxable years involved in the computati…
  7. 87 FR 80042 — Exception for Interests Held by Foreign Pension Funds
    IRCFinal Rules (FR)Dec 29, 2022related by meaning
    ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development. ( printed page 80055) List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended a…
  8. Treas. Reg. § 1.72-18(d)(2) — Treatment of certain total distributions with respect to self-employed individuals.
    IRCRegulationsMar 14, 2019
    … year, without regard to the distribution, he had a net operating loss and is allowed under section 151 a deduction for one personal exemption. At the time of the withdrawal, B was 64 years old. The amount of the distribution that is includible in his gross income is $25,750. Because of B's net operating loss, the tax …
  9. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000related by meaning
    994 and 1995 tax liabilities. We grant respondent's motion for a penalty under section 6673. Under section 6673, this Court may award a penalty to the United States of up to $25,000 when the proceeding has been instituted or maintained by the taxpayer primarily for delay or if the taxpayer's position in such proceeding…
  10. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …s: [(1,835 broker-dealers + 15,775 registered investment advisers) × (30 minutes ÷ 60 minutes)] + [(151 insurers + 10 robo-advisers + 930 pension consultants + 20 investment company underwriters) × 1 hour] = 9,896 hours. A labor rate of $159.34 is used for a legal professional. The labor rate is applied in the followin…
  11. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …3 28,899 -0- 28,899 6,684 -0- 6,684 1982 27,881 -0- 27,881 6,412 -0- 6,412 1981 26,899 -0- 26,899 6,151 -0- 6,151 1980 25,952 -0- 25,952 5,900 -0- 5,900 1979 25,037 -0- 25,037 5,660 -0- 5,660 1978 24,155 -0- 24,155 5,429 -0- 5,429 1977 23,304 -0- 23,304 5,208 -0- 5,208 1976 22,484 -0- 22,484 4,996 -0- 4,996 1975 21,691…
  12. 78 FR 53704 — Employee Retirement Benefit Plan Returns Required on Magnetic Media
    IRCProposed Rules (FR)Proposed Aug 30, 2013related by meaning
    ublic hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the Federal Register . Drafting Information The principal authors of these regulations are William Gibbs and Pamela R. Kinard, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities…
  13. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …e Plan included the following information: 1990 1991 1992 1993 1994 Fund value at yearend $100,281 $151,615 $150,370 $160,563 $169,572 Contribution in transit-0-55,000-0 - - 0 - - 0 - Policy values-0-96,219 149,983 160,176 169,181 Surrender value N/A 90,412 141,438 151,632 160,636 Additional contrib. available 3,976 4,…
  14. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    tely $1,026,855 in U. S. currency deposited into various bank accounts during the period January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts alleging violations of customs reporting requirements. On January 9, 1992, petitioner entered into a plea a…
  15. Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o…
    IRCRevenue ProceduresOct 17, 2016related by meaning
    sing Form 8821, Tax Information Authorization. (See Form 8821 and Instructions) See section 10.09 for special rules relating to Anonymous Submissions. .08 Penalty of perjury statement. (1) The Plan Sponsor must sign the penalty of perjury statement on the Form 8950 as part of a VCP submission. In addition, the followin…
  16. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    at trial that he had filed a return for 2012 showing tax due. Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual payment …
  17. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …16/90 18,000.00 18,911.25 20,874.18 1,962.93 1/01/91 1,675.86 1 $1,676.00 1,804.87 128.87 5/22/91 2,151.47 1 2,151.00 2,259.89 108.89 3/24/92 2,500.00 6/17/92 5,000.00 __________ _________ __________ 3,827.00 6,986.75 55,941.57 $66,755.32 1 The difference between the principal amounts of the loans petitioner received i…
  18. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  19. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997
    …D). After the conclusion of trial, the Court directed the parties to file seriatim briefs. See Rule 151(b). Petitioners' opening brief includes 8 pages of proposed findings of fact. See Rule 151(e)(3). Respondent's answering brief includes 5 pages of objections to petitioners' proposed findings of fact and 4 pages of r…
  20. T.C. Memo. 2025-23 — Charlie Campana v. Commissioner
    IRCCourt RulingsMar 19, 2025related by meaning
    United States Tax Court T.C. Memo. 2025-23 CHARLIE CAMPANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent __________ Docket No. 15766-23. Filed March 19, 2025. __________ Charlie Campana , pro se. Bianca L. Thomas and Daniel C. Munce, for respondent. MEMORANDUM FINDINGS OF FACT A ND OPINION PUGH , Judge : …