IRCCourt RulingsAug 23, 2016related by meaning
th respect to Ms. Barie's IRA distribution. Section 72(t)(1) provides:
SEC. 72. ANNUITIES; CERTAIN PROCEEDS OF ENDOWMENT
AND LIFE INSURANCE CONTRACTS. (t) 10-Percent Additional Tax on Early Distributions from
Qualified Retirement Plans.--
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qua…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
Notice 2026-26 — Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates IRCNotices
…d 2026 were published in Notice 2024-6 7 , 2024-4 1 I.R.B. 726 and Notice 2025- 47, 2025- 40 I.R.B. 441, respectively.
1
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine
the current liability of a CSEC plan (which is used to calculate the minimum amount of the full…
IRCCourt RulingsJul 13, 2010
…mpson v . Commissioner , 78 T .C . 558, 561 (1982), an d
Phillips v . Commissioner , 86 T .C . 433, 441 n . :7 : (1986), affd . as
to this issue 851 F .2d 1492 (D .C : Cir . .1988))` .
16
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCPrivate Letter RulingsNov 14, 2008
…week taxable year ending in December, rather than a calendar year
taxable year, see Treas. Reg. § 1.441-2(d).
IRCCourt RulingsFeb 26, 2014related by meaning
ount (IRA); (2) are liable for the 10% additional
tax under section 72(t); and (3) are liable for the accuracy-related penalty under
section 6662(a).' A few of the facts have been stipulated and are so found. The stipulation of
facts and the exhibits received in evidence are incorporated herein by reference.
Petitioner…
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975related by meaning
rough with the plan, it could doubtless have met and resolved to abandon it, without subjecting petitioner to liability to anyone. [19 T.C. at 26-27.] See also Precision Industries, Inc., 64 T.C. 901 (1975), recently decided by this Court.
Decision will be entered for the respondent
All section references are to the In…
IRCCourt RulingsJan 29, 2019related by meaning
tiation rules. Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per
curiam, 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary Income Tax Regs., supra. These strict substantiation rules generally require the taxpayer to
substantiate with adequate records or by sufficient evidence corroborating the
taxpayer…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * 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 w…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
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 11, 2012
… or calculations. See Gen. Star Nat'l Ins. Cò. v. Administratia
Asigurarilor de Stat, 289 F.3d 434, 441 (6th Cir. 2002) (undeveloped legal
arguments waived); Muhich v. Commissioner, 238 F.3d 860, 864 n.10 (7th Cir.
2001), aff g T.C. Memo. 1999-192.
3
- 54 -
evidence indicating that it is appropriate to impose the penal…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967related by meaning
dic or annual compensation on the basis of permanent employment;
(c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…
IRCCourt RulingsApr 16, 2020
… have the burden of proof with
respect to that issue. See Higbee v. Commissioner, 116 T.C. 438, 440-441 (2001).
Because we resolve these cases on the preponderance of the evidence and without
regard to the burden of proof, we do not decide whether sec. 7491(a) applies here.
- 13 -
[*13] wife received $69,502 in gross p…
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 RulingsMay 8, 2017
…s originally conferred on the deceased spouse
- 12 -
[*12] (citing United States v. Basye, 410 U.S. 441, 447 (1973); Commissioner v.
Culbertson, 337 U.S. 733, 739-740 (1949); New Colonial Ice Co. v. Helvering,
292 U.S. 435 (1934); and Lucas v. Earl, 281 U.S. 111, 114-115 (1930))). "[A]