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57 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    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…
  2. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n has been previously rejected by this Court as baseless and subject to the imposition of sec. 6673 penalties. See Waltner v. Commissioner, T.C. Memo. 2014-35, , __ F. App'x __, 2016 WL 5800492 (9th Cir. Oct. 5, 2016); Nelson v. Commissioner, T.C. Memo. 2012-232, M, 540 F. App'x 924 (11th Cir. 2013). - 10 - [*10] suppo…
  3. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    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…
  4. 127 T.C. No. 1 — Charlotte & Charles T. Gee v. Commissioner
    IRCCourt RulingsJul 24, 2006related by meaning
    petitioners' Federal income tax for 2002 and determined that petitioners are liable for the accuracy-related penalty under section 6662(a)' for 2002 . There are two issues for decision . The first issue is whether a $977,888 distribution petitioner Charlotte Gee (petitioner) received in 2002 from an individual retireme…
  5. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983related by meaning
    endered by a self-employed individual were intended tó be treated as attributable to capital, taxable without regard to the section 1348 limitations.7 To aid in determining whether capital is material to the production of the income, the regulations set forth guidelines drawn mainly from the decided cases interpreting …
  6. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  7. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    ying that the regulation might have utilized different language to achieve its stated purpose. II. Validity of Section 1.415-5(c)(1), Income Tax Regs. Respondent asserts that section 1.415-5(c)(l), Income Tax Regs., is appropriate either as a "legislative” regulation specifically authorized by section 415(d)(1)(A) or a…
  8. T.C. Memo. 2012-300 — Churchill, LTD. Employee Stock Ownership Plan & Trust v. Commissioner
    IRCCourt RulingsOct 25, 2012related by meaning
    hall include compensation which is not currently includible in the Participant's gross income by reason of the application of sections 125, 402(a)(8), 402(h)(1)(B), or 403(b) of the Code, but shall not exceed $200,000 for any Plan Year. -15- [*15] In the second amendment to the 1989 plan the definition of "compensation…
  9. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  10. REG-118988-22 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Feb 18, 2025related by meaning
    nt of the Code, including all rules and regulations as may be necessary by reason of any alteration of law in relation to internal revenue. Background This document sets forth proposed amendments to the Income Tax Regulations (26 CFR part 1) under section 162(m). Section 162(m)(1) disallows a deduction by any publicly …
  11. T.C. Memo. 2012-213 — Mark William Murray v. Commissioner
    IRCCourt RulingsJul 25, 2012related by meaning
    to the lesser of (1) 90% of the tax shown on the return for the taxable year (or, if no return is filed, 90% of the tax for that year), or (2) 100% of the tax shown on the return, if any, for th preceding ta able year. Sec. - 11 - 6654(d)(1)(B). Petitioner did not file Federal income tax returns for the taxable years 2…
  12. T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen…
    IRCTreasury DecisionsFeb 26, 2007related by meaning
    tal wages. The regulations apply to all employers and others making supplemental wage payments to employees. Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…
  13. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
  14. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    o. 17204-09 Additions to tax and penalty Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)' Sec. 6662A 2004 $28,779 $1,179.23 to be determined $9,259.32 2005 83,908 2,131.20 to be determined . 21,855.65 2006 62,339 3,645.68 to be determined 13,879.43 1Respondent explains in the notice of deficiency that the additions to …
  15. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  16. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
  17. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012related by meaning
    ditional tax provided by section 72(t)), penalties, and statutory interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record . 12 - does not establish that petitioners received a.notice of deficiency for 2007 and consequently a challenge to petitioners' 2007 tax liability is allowed in thi judicial p…