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65 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020★ strong match
    … is incomplete for this reason as having been waived. See Mendes v. Commissioner, 121 T.C. 308, 312-313 (2003). The second concern regarding fact-type documents is that the record contains fact-type documents upon which Keen did not rely. Here, Goldberg has had a proper opportunity for a hearing at the Office of Appeal…
  2. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    includible in income under section 61(a)(12) and subject to tax. However, this issue is moot because petitioners' debts were not discharged but rather extinguished, and thus petitioners' income was not from discharge of indebtedness. III. Accuracy-Related Penalty Section 6662(a) imposes an accuracy-related penalty equa…
  3. PLR 200005001 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsFeb 4, 2000
    … under the Bankruptcy Code. Relying on earlier decided cases, such as City of New York v. Feiring , 313 U.S. 283, and United States v. New York , 315 U.S. 510 (1942), the Court reasoned that the operation of the provision using the term in question, not the label placed on the exaction, is dispositive of the exaction’s…
  4. 89 FR 12955 — Management of Federal Agency Disbursements
    IRCFinal Rules (FR)Feb 21, 2024related by meaning
    l.treasury.gov, or Rebecca Saltiel, Senior Counsel, at (202) 874-6648 or Rebecca.Saltiel@fiscal.treasury.gov. SUPPLEMENTARY INFORMATION: I. Background In 1998, Fiscal Service issued a final rule, codified at 31 CFR part 208 (part 208), to implement the requirements of 31 U.S.C. 3332, as amended by section 31001(x)(1) o…
  5. PLR 202315010 — Deferred Compensation
    IRCPrivate Letter RulingsApr 14, 2023
    … and, thereby, accelerate the timing of the deduction of such deferred compensation. S. Rep. No. 99-313 , 1013 (1986). Accordingly, even if the unpaid loss adjustment expenses would ordinarily be taken into account as part of its losses incurred under § 832(b)(5), the deduction timing rules in § 404(a)(5) take preceden…
  6. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    , 3207-22, - 7 - 3 U.S. Const. amend. V provides "nor shall any person be subject for the same offence to be twice put in jeopardy of life or limb". 4 U.S. Const. amend. VIII provides "Excessive bail shall not be required, nor excessive fines imposed". we think it clear that allowance of petitioner's claimed deduction …
  7. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    test imposition of the penalty on the underpayment caused by the disallowed operating loss deduction is based on terms of the harshness of the result. Section 6653(a) does not permit allocating the penalty to specific adjustments made to the return. If “any part of any underpayment” is due to fraud, the addition to the…
  8. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  9. T.C. Summary Opinion 2014-84 — David C. Matthews & Marcia K. Matthews v. Commissioner
    IRCCourt RulingsAug 28, 2014
    …hat such expenses exceed 7.5 percent of adjusted gross income."4 Petitioners' AGI for 2011 was $250,313, and they paid $9,189 in unreimbursed medical expenses that year. Because petitioners' unreimbursed medical expenses did not exceed $18,773 (7.5% of $250,313)--the floor for an allowable deduction under section 213--…
  10. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    ddition to tax must be sustained. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or groundless or the taxpayer has instituted or pursued the proceeding primarily for delay. Respondent has n…
  11. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997
    …d capital gains treatment. On the original return, petitioners reported a gross distribution of $25,313, indicating that $9,202 was the taxable amount and $3,324 was capital gain. Petitioners submitted an amended return for 1990 (first amended return) in February 1996, on which petitioners did not elect 5-year averagin…
  12. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    e of Information and Regulatory Affairs designated this rule as a major rule as defined by 5 U.S.C. 804(2). Statement of Availability of IRS Documents The IRS Revenue Procedures, Notices, and other guidance cited in this preamble is published in the Internal Revenue Bulletin and is available from the Superintendent of …
  13. I.R.C. § 6662(i) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (i) (i) Increase in penalty in case of nondisclosed noneconomic substance transactions (i)(1) (1) In general In the case of any portion of an underpayment which is attributable to one or more nondisclosed noneconomic substance transactions, subsection (a) shall be applied with respect to such portion by substituting "4…
  14. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974
    … is actually made” within the prescribed period. The cases of Wasatch Chemical Co. v. Commissioner, 313 F.2d 843 (C.A. 10, 1963), reversing 37 T.C. 817 (1962); Time Oil Co. v. Commissioner, 258 F.2d 237 (C.A. 9, 1958), reversing 26 T.C. 1061 (1956); and Sachs v. Commissioner, 208 F.2d 313 (C.A. 3, 1953), reversing Slay…
  15. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
    IRCCourt RulingsJun 24, 1966
    …a) (1), I.R.C. 1954; Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); General Smelting Co., 4 T.C. 313, 320; Associated Theatres Corporation, 14 T.C. 313, 320; Perel & Lowenstein, Inc. v. Commissioner, 237 F. 2d 908 (C.A. 6, 1956), affirming per curiam a Memorandum Opinion of this Court. On the second issue the materi…
  16. 88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    dent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at http://www.irs.gov. Drafting Information The principal author of these final regulations is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). Other personnel from the …
  17. 62 T.C. 166; 14 U.C.C. Rep. Serv. (West) 1165 — Don E. Williams Co. v. Commissioner
    IRCCourt RulingsMay 14, 1974
    …(1949); Slaymaker Lock Co., 18 T.C. 1001 (1952), reversed sub nom. Sachs v. Commissioner, 208 F. 2d 313 (C.A. 3, 1953); Time Oil Co., 26 T.C. 1061 (1956), revd. 258 F. 2d 237 (C.A. 9, 1958); Wasatch Chemical Co., 37 T.C. 817 (1962), revd. 313 F. 2d 843 (C.A. 10, 1963). An appeal in the instant case would lie in the Cou…
  18. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    acted in good faith with respect to such portion. ” Unlike the reasonable cause and good faith exception found in section 6664(c), Congress placed the adequate disclosure exception in section 6662(d), with no text indicating that it was meant to apply to multiple section 6662 penalties. The reason for t his is apparent…
  19. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  20. PLR 200226001 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsJun 28, 2002
    …lities those assets may be paid , as a reversion, to the employer. (Emphasis added.) S. Rep. No. 99-313 at 635 (1985) (1986-3 C.B. Vol. 3 at 635) contains the identical provision. H.R. Rep. No. 99-426 at 757 also states Code § 4980 is effective for “ ... a reversion received pursuant to a plan termination occurring aft…