IRCCourt RulingsMay 29, 1997
… year although a deduction was permitted in
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To ref…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsJun 29, 1956
… or designated beneficiary. Of the amount of $36,608.83 received by the petitioner, an amount of $8,970.41 was tax exempt as it represented decedent’s unrecovered cost. The taxable amount received by the petitioner was $27,638.42.
IRCCourt RulingsApr 16, 2020
…014.
TW Telecom provided petitioner wife Forms W-2, Wage and Tax
Statement, reporting wages of $236,970 and $353,365 for 2013 and 2014,
respectively. For 2014 her Form W-2 wages comprised, among other forms of
- 11 -
[*11] compensation, $63,566 for the exercise of the stock options that year.
Petitioners reported petit…
IRCCourt RulingsDec 18, 2012related by meaning
evidence. In addition, we decline to apply the Cohan rule to approximate
itemized deductions because petitioners failed to comply with our orders, and they have not built a sufficient evidentiary foundation from which we can apply
the Cohan rule to approximate any itemized deductions to which they are entitled.
We also…
IRCCourt RulingsMay 19, 2011related by meaning
Sanction Awarded by the Court
We now consider sua sponte whether to impose a penalty
against petitioner pursuant to section 6673(a) (1). That section allows the Court to impose upon a taxpayer a penalty of up to
$25,000 whenever it appears that the taxpayer instituted or
maintained a proceeding primarily for delay or …
IRCCourt RulingsDec 19, 2016
…sonable cause or substantial authority. See Rule 142(a); Longino v.
Commissioner, 593 F. App'x 965, 970 (1 l th Cir. 2014), T.C. Memo. 201380; Higbee v. Commissioner, 116 T.C. at 446-447. Respondent has met his
burden here.
No penalty may be imposed under section 6662 with respect to any portion
of an underpayment upon…
IRCCourt RulingsFeb 6, 2012related by meaning
to deduct the contributions she made to her
pension plan; and (2) whether petitioner is liable for an accuracy-related penalty
under section 6662(a).3 i Unless otherwise indicated, all section references are to the Internal
Revenue Code (Code) in effect for the year in issue, and all Rule references are to
the Tax Cour…
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980
…rvice Center, Philadelphia, Pa. On that return, petitioner claimed a deduction in the amount of $30,970.89 as a contribution to its profit-sharing plan.
The contribution was made under a profit-sharing plan and trust agreement adopted on February 28,1968. During the 1973 fiscal year, the two trustees of the trust, Joe …
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsFeb 6, 2024related by meaning
at *11 ;
Schroeder, 78 T.C.M. (CCH) at 568. Petitioner constructively received
and must include in his gross income a taxable distribution of $427,518 from his retirement account with T. Rowe Price.
III. Additions to Tax
In the Notice , respondent determined that petitioner was liable
for an addition to tax of $ 37,204…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsFeb 25, 2014
…iling status was $53,000. Sec. 219(g)(3)(B)(ii), (8); Rev.
Proc. 2007-66, sec. 3.22(2), 2007-2 C.B. 970, 975. Consequently, for the 2008 tax
year the IRA contribution deduction was completely phased out for an individual
taxpayer with AGI exceeding $63,000. See Wade v. Commissioner, T.C. Memo.
2001-114, 2001 WL 505210,…
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
IRCCourt RulingsMar 27, 1963
…_ 807.35
13_ __ 827.61
14_ __ 848.70
15_ __ 870.71
16_ __ 893.76
17_ __ 918.01
18_ __ 943.64
19_ __ 970.87
20_ 1, 000. 00
With respect to the payment of dividends the policy provided:
Dividends
IRCCourt RulingsJan 31, 2012
…out at a combined adjusted gross income of
$105,000. See Rev. Proc. 2007-66, sec. 3.22, 2007-2 C.B. 970, 975.
Xu and Cai reported a combined total income of $119,616 on their 2008
joint Federal income tax return. After adjustment for the $ 6 penalty on early
withdrawal of savings, their applicable modified AGI was $119…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsFeb 28, 2024related by meaning
luded that
the bulk of the $26 million received by hi s IRA was attributable to his
relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…
IRCCourt RulingsJun 6, 2005related by meaning
a matter of
legislative grace, and the burden of clearly showing the right to
the claimed deduction is on the taxpayer. INDOPCO, Inc. v.
Commissioner , 503 U.S. 79, 84 (1992). We are bound by the
Internal Revenue Code, and it is within the province of the
legislature to decide the circumstances of inclusion, deductions…