IRCCourt RulingsFeb 6, 2024related by meaning
icipation. Id.
Thus, even though the withdrawal from the taxpayer’s Keogh account
was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively
receive the funds under section 72(m)(4)(A).
4
In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
ERISARegulationsJan 1, 2017related by meaning
(j) (j) Liability.
(j)(1) (1) If more than one person is responsible as administrator for the failure to file the annual report, all such persons shall be jointly and severally liable with respect to such failure.
(j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(2) pursuant to a…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
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 : …
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
- 6 -
Respondent does not dispute that petit…
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
added to the aggregate unpaid balance of all preceding such payments for which payment was not made when due (including interest), exceeds $1 million. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due.
(2) If a contributing spo…
89 FR 104915 — Regulations Governing Practice Before the Internal Revenue Service IRCProposed Rules (FR)Proposed Dec 26, 2024related by meaning
d submit the report to the office(s) of the Internal Revenue Service responsible for administering and enforcing this part.
(c)
Destruction of report. No report made under paragraph (a) or (b) of this section will be maintained unless retention of the report is permissible under the applicable records control schedule …
IRCCourt RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
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 …