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74 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015related by meaning
    mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo. 2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144. - 12 - II. Section 1839 A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and necessary expenses incurred in conducting a trade or business or for the production of income. Se…
  2. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  3. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999
    113 T.C. No. 9 UNITED STATES TAX COURT SKLAR, GREENSTEIN & SCHEER, P.C., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11386-97. Filed August 13, 1999. P is a corporation which provides medical services and is a sponsor of a qualified deferred compensation plan (the plan). S, G, and E were peti…
  4. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  5. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    so. Despite the fact that Mrs. Colombell received no tax benefit whatsoever from her “participation” in Inova’s retirement plan, the Court is not free to rewrite the law. See, e.g., Hildebrand v. Commissioner , 683 F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v. Commissioner , 661 F.2d 53, 54-55 (5th …
  6. Notice 2010-83 — Funding relief for multiemployer defined benefit plans under PRA 2010. This notice provides guidance in the form of questions and answers for sponsors of multi…
    IRCNoticesDec 20, 2010
    … market value as of the end of 2008 ($161.50) minus the actual market value as of the end of 2008 ($113.50)) and the plan sponsor has decided to apply the special amortization rule of § 431(b)(8)(A) to that eligible net investment loss. (d) Under the asset valuation method for the plan, the actuarial value of assets on…
  7. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
  8. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  9. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  10. Treas. Reg. § 1.72-5(b)(3) — Expected return.
    IRCRegulationsJul 26, 2016
    … and the basis of the surviving annuitant's interest in the contract was determinable under section 113(a)(5) of the Internal Revenue Code of 1939, such basis shall be considered the “aggregate of premiums or other consideration paid” by the surviving annuitant for the contract. (For rules governing this determination,…
  11. T.C. Summary Opinion 2008-160 — Renita Rose Best v. Commissioner
    IRCCourt RulingsDec 23, 2008related by meaning
    v . Commissioner , 111 T .C . 250, 255 (1998) ; Milner v . Commissioner , T .C . Memo . 2004-111 ; Gallagher v . Commissioner , T .C . Memo . 200134 . We conclude that petitioner is liable for the $1,971 10percent additional tax on her early $19,706 IRA distribution . Decision will be entere d for respondent .
  12. Treas. Reg. § 1.401(a)(9)-9(d) — Life expectancy and distribution period tables.
    IRCRegulationsSep 17, 2024
    …3.2 3.1 3.1 3.0 3.0 111 3.7 3.5 3.4 3.3 3.2 3.1 3.0 3.0 3.0 112 3.7 3.5 3.4 3.3 3.2 3.1 3.0 3.0 3.0 113 3.6 3.5 3.4 3.2 3.1 3.1 3.0 3.0 2.9 114 3.6 3.5 3.3 3.2 3.1 3.0 3.0 2.9 2.9 115 3.6 3.4 3.3 3.2 3.1 3.0 2.9 2.9 2.9 116 3.5 3.3 3.2 3.1 3.0 2.9 2.8 2.8 2.8 117 3.4 3.3 3.1 3.0 2.9 2.8 2.7 2.7 2.7 118 3.3 3.1 3.0 2.8 …
  13. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  14. 29 C.F.R. § 2509.94-3 — Interpretive bulletin relating to in-kind contributions to employee benefit plans.
    ERISARegulationsJan 1, 2017
    …Code.In Commissioner of Internal Revenue v. Keystone Consolidated Industries, Inc., ____ U.S. ____, 113 S. Ct. 2006 (1993), the Supreme Court held that an employer's contribution of unencumbered real property to a tax-qualified defined benefit pension plan was a sale or exchange prohibited under section 4975 of the Cod…
  15. T.C. Memo. 2010-186 — Kwame Owusu v. Commissioner
    IRCCourt RulingsAug 23, 2010related by meaning
    not a distribution of dividends on an employer's securities by an employee stock ownership plan . Further, the deemed distribution occurred only once ; it was therefore not part of a series of substantially equal periodic payments over the life of petitioner . There is also no evidence in the record that petitioner ha…
  16. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  17. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ddress the income tax consequences of the recharacterization of the DISC commissions. However, respondent's position that a transaction may be treated differently under different tax regimes seeds, on the surface, to have some support in 'cases which have held -that the income and gift tax statutes are not read in conj…
  18. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …,750 -- -- -- -- -- B Equipment--F&F 8/11/2003 1,513 1,513 -- -- -- A Equipment--Henn. 8/13/2003 19,113 19,113 -- -- -- B 1510 Equipment-- Alpha 9/8/2003 6,500 6,500 -- -- -- -- -- E Equipment--Krom. 10/20/2003 5,850 5,850 -- -- -- E 1520 Equipment-- Alpha 10/31/2003 9,800 9,800 -- -- -- E 1620 w/RC Equipment--Krom. 12…
  19. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  20. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    rary purpose has been shown here. Because we are satisfied that our analysis of section 4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A. - 11…