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41. T.C. Memo. 2016-215 — Glen A. Blair v. Commissioner
    IRCCourt RulingsNov 23, 2016
    …previous year'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 war…
42. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998related by meaning
    mulgated under the general rulemaking power vested in the Secretary by section 7805(a). Peterson Marital Trust v. Commissioner , 102 T.C. 790, 797-798 (1994), (and cases cited therein), affd. 78 F.3d 795, 798 (2d Cir. 1996). Section 1.7476-1(b), Income Tax Regs. (relating to interested parties), has been promulgated un…
43. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    IRCCourt RulingsJan 22, 2025
    …ient evidence that the tax was shown on a f ederal income tax return and was not paid. See Wheeler, 127 T.C. at 210; Worsham v. Commissioner , T.C. Memo . 2012-2 19 , slip op. at 21 – 22 , aff’d , 531 F. App ’ x 310 (4th Cir. 2013). In a case such as this where the taxpayer has not filed a f ederal income tax return fo…
44. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
45. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014
    …(a)(2) addition to 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 se…
46. 127 T.C. No. 1 — Charlotte & Charles T. Gee v. Commissioner
    IRCCourt RulingsJul 24, 2006
    127 T .C . No . 1 UNITED STATES TAX COUR T CHARLOTTE AND CHARLES T . GEE, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 8755-05 . Filed July 24, 2006 . P rolled over a distribution from her deceased husband's individual retirement account (IRA) into her separate IRA upon her husband's death …
47. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    tter of local law and a State court's determination with regards to such assignment is not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of Bosch, 387 U.S. 456, 465 (1967), the Court held that where the Federal estate tax liability turns upon the chara…
48. T.C. Summary Opinion 2004-127 — Rowland Setyono v. Commissioner
    IRCCourt RulingsSep 13, 2004
    T.C. Summary Opinion 2004-127 UNITED STATES TAX COURT ROWLAND SETYONO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5500-03S. Filed September 13, 2004. Rowland Setyono, pro se. John D. Faucher , for respondent. DEAN, Special Trial Judge : This case was heard pursuant to the provisions of secti…
49. 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).
50. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …ments to Weekend Warrior's 2003 and 2004 Forms 1120S as follows: Adjustment 2003 2004 Depreciation $127,859 $127,829 Repairs and maintenance--aircraft 27,600 27,600 Other--insurance aircraft 15,000 15,000 other deductions--aircraft fees 429 429 Other deductions--pilot 3,947 3,947 Management fees 4,800,000 4,595,000 Bal…
51. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
52. I.R.C. § 414(n)(3) — Definitions and special rules
    IRCCode / StatuteJan 6, 2025
    …) sections 408(k), 408(p), 410, 411, 415, and 416, and (n)(3)(C) (C) sections 79, 106, 117(d), 125, 127, 129, 132, 137, 274(j), 505, and 4980B. (n)(4) (4) Time when first considered as employee (n)(4)(A) (A) In general In the case of any leased employee, paragraph (1) shall apply only for purposes of determining whethe…
53. U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner
    IRCCourt RulingsJun 26, 2018
    …pondent incorrectly asserts that petitioner withdrew Exhibits 110-P through 120-P and 123-P through 127-P introduced during the hearing. Only Exhibits 110-P through 114-P were withdrawn. Respondent used the remaining exhibits during the hearing despite objecting to their admissibility. The Court reserved ruling on Exhi…
54. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
55. 70 T.C. 214; 1 Employee Benefits Cas. (BNA) 1835 — Automated Packaging Systems, Inc. v. Commissioner
    IRCCourt RulingsMay 15, 1978
    mit the plan’s vesting schedule to remain unchanged. [S. Rept. 93-127, 93d Cong., 1st Sess. 39, reprinted in U.S. Code Cong. & Adm. News 4875 (1974).] Moreover, the elapsed time method is an alternative method which was promulgated by the Secretary of Labor to accommodate employers who objected to the restrictive natur…
56. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    for all of the Plan years due, on April 1, 1999. (T 127) He mailed the individual participation benefit statements for Plan year 1997 about two weeks later, (T 127) which they were able to do as a result of the computerization work that had been done for the previous Plan years. (T 128) He did not receive any objectio…
57. T.C. Memo. 2000-250 — Susan Jane Hoyez, C.P.A. v. Commissioner
    IRCCourt RulingsAug 10, 2000related by meaning
    6, 682 (1977); Pawlak v. Commissioner , T.C. Memo. 1995-7. Finally, there is no indication - 8 - 2 Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be retroactively applied to the previous year if the contributions are made by the due date of the employer’s r…
58. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    … that she had first requested in the September 2007 IDR. See supra pt. III.Z, p. 124 (Period 16). - 127 - [*127] On December 23, 2010, Goldberg emailed RA Knighton, telling her that he intended to file a "1203"46 complaint against Buffamonte, who had been RA Knighton's group manager but (as of December 23, 2010) no lon…
59. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …rs on average to prepare and send requested records, resulting in a per request equivalent cost of $127.[180] The Department expects that such requests would occur rarely. As such, the Department estimates that one request a year would result in an average annual burden of $127. 11. Summary The paperwork burden estimat…
60. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…