IRCCourt RulingsJun 4, 2014
…nformation formed the basis
of the Government's action against the target taxpayers.
W filed a Form 211, Application for Award for Original
Information, in 2008 and submitted to R documentary evidence
related to W's involvement in the Government's investigation. W
resubmitted Form 211 in 2011 seeking an award under I.R…
IRCCourt RulingsAug 27, 2026
…indicia or “badges” of
fraud to find circumstantial evidence of fraud. See Niedringhaus, 99 T.C.
at 211; DiLeo , 96 T.C. at 875. These badges of fraud include , as
potentially relevant here, understating income; failing to maintain
adequate records; offering implausible or inconsistent explanations of
behavior; failing…
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…
IRCProposed Rules (FR)Proposed May 13, 2026related by meaning
URY
Internal Revenue Service
Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 54 as follows:
PART 54—PENSION EXCISE TAXES 1. The authority citation for part 54 continues to read as follows:
Authority:
26 U.S.C. 7805, unless otherwise noted.
2. Section 54.9831-1 is amended by—
a. Revising pa…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsOct 3, 1995related by meaning
ch amount is received shall be
increased by an amount equal to 10 percent of the
portion of such amount which is includible in gross
income.
- 18 -
16 We also observe that the Transfer Refund was paid to
petitioner "on account of" his election to transfer from the
Retirement System to the Pension System and not "on acc…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
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…
76 FR 60373 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Sep 29, 2011related by meaning
…nal Revenue Service
26 CFR Part 301
[TD 9545]
RIN 1545-BG75
Correction
In rule document number 2011-21164 beginning on page 52259 through 52263 in the issue of August 22, 2011, make the following corrections:
301.6404-4
[Corrected]
1. On page 52262 in the second column, in § 301.6404-4(a)(7)(i) third paragraph, 15 line…
IRCCourt RulingsJul 31, 2000
… for the
respective years from 1991 through 1993: Dr. and Ms.
Hirshkowitz-–$254,051, $136,678, and $211,120; Dr. and Ms. Desai-
–$122,750, $42,056, and $55,000; Dr. and Ms. McManus-–$20,000,
$17,921, and $18,186; and the Estate of Steven Sobo, Deceased,
- 60 -
20
In summary, respondent determined that the disallowed
co…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsAug 27, 2008
…red to make
an annual payment under section 6654(d)(1)(B) . See Wheeler v .
Commissioner , supra at 211 . The amount of any required annual
- 10 - payment is the lesser of (1) 90 percent of the tax shown on the
individual's return for the year or, if no return is filed, 90
percent of his or her tax for such year, or (2…
IRCCourt RulingsNov 12, 1997
…ordingly
increased petitioner's taxable income by $40,355. Moreover,
respondent disallowed all but $211 of petitioner's $33,943
investmen t interest expense deductions on the basis that
petitioner's offsetting investment income was only $211.
Respondent also determined that petitioner had only substantiated
$29,443 of …
IRCCourt RulingsNov 23, 2016
…r's return exceeds $150,000, a
higher percentage may apply).
¹5Wheeler v. Commissioner, 127 T.C. at 211.
- 10 -
[*10] under section 6654(d)(1)(B).¹6 Accordingly, Mr. Blair is not liable for a
section 6654 addition to tax.
V. Mr. Blair Is Liable for a Section 6673 Penalty.
A section 6673(a)(1) penalty is warranted if th…
IRCCourt RulingsJul 21, 2014
… tax, the IRS must introduce into
evidence a tax return. Wheeler v. Commissioner, 127 T.C. 200, 208-211 (2006),
aff'd, 521 F.3d 1289 (10th Cir. 2008). This can be done by introducing a copy of
the SFR into evidence or by stipulation of the parties that the SFR is valid and
meets the requirements of section 6020. See, e…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
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- - -
IRCCourt RulingsJan 13, 1958related by meaning
This subsection shall be applicable to all contracts and subcontracts, to the extent of amounts received or accrued thereunder in any fiscal year ending after June 30, 1943, whether such contracts or subcontracts were made on, prior to, or after the date of the enactment of the Revenue Act of 1943, and whether or not s…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
T.D. 9987 — These regulations provide guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These regulations pr… IRCTreasury DecisionsFeb 5, 2024related by meaning
lt in expenditures by State, local, or Tribal governments, or by the private sector in excess of that threshold.
4. Executive Order 13132 (Federalism) Executive Order 13132 (Federalism) prohibits an agency from publishing any rule that has federalism implications if the rule either imposes substantial, direct complianc…