IRCCourt RulingsMay 25, 2006
…eceived.
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4
The Economic Growth and Tax Relief Reconciliation Act of
2001 Pub. L. 107-16, sec. 643(a), 115 Stat. 122, provides:
(a) Rollovers From Exempt Trusts.--Paragraph (2) of
section 402(c) (relating to maximum amount which may be
rolled over) is amended by adding at the end the following:
IRCCourt RulingsOct 12, 1978related by meaning
levant documents comprising the application for determination. Such information was furnished to the Department of Labor by the IRS on April 20, 1977. On May 25, 1977, the Commissioner notified the trustees of Central that its plan, as amended effective January 30, 1976, was qualified, provided it adopted the additiona…
IRCCourt RulingsMay 5, 2008related by meaning
T .C . Summary Opinion 2808-4 9
UNITED STATES TAX COUR T
ANDREA C . CASULA, Petiti
COMMISSIONER OF INTERNAL REVENI
ner v .
E, Responden t
Docket No . 3385-05S . Filed May 5, 2008 .
Paul Kalinich (specially recognized)', for petitioner .
Mayer Silber , for respondent .
RECORDE D
S .T . JUDG E
GOLDBERG, Special Trial Jud…
ERISACourt RulingsAug 14, 2026
…und within the language of the contract itself. See Much v. Pac. Mut. Life Ins. Co. ,
266 F.3d 637, 643 (7th Cir. 2001); Camico Mut. Ins. Co. v. Citizens
Bank , 474 F.3d 989, 993 (7th Cir. 2007). The former is a subset
of the latter; thus, we have said, “to be admissible to create an
ambiguity in a clear-seeming writte…
IRCCourt RulingsMar 7, 2019
…corporate returns for the years at
issue:
Year Total income Total deductions Taxable income
2003 $1,643,523 $1,550,807 $92,716
2004 1,488,793 1,390,853 97,940
2005 1,688,916 1,693,882 (4,966)
2006 1,903,914 1,884,065 14,883¹4
¹³ BAI's fiscal year ends June 30. Therefore, all references to BAI's tax
years at issue refer…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
… Petitioner cites James M. Pierce Corp.
v. Commissioner, 326 F.2d 67 (8th Cir. 1964), rev’g 38 T.C. 643 (1962),
and Commercial Security Bank for the proposition that either the buyer
assumes the liability and pays the seller the net cash amount or the
buyer pays the gross cash amount and the seller uses a portion to sa…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
IRCCourt RulingsJun 17, 1997
…
the following information:
Taxable year ended 09/30/90
09/30/91
09/30/92
09/30/93
Total income $51,643 $725,000 $606,132 $909,028
Compensation of officers-0-303,200 102,200 143,000
Salaries & wages 20,481 1,000 1,000 7,855
Pension, profit-sharing, plans-0 - - 0 - - 0 - - 0 -
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
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(3) If at any time the correction of the
error is authorized as to one such t…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
acted section
7476 to establish a declaratory judgment procedure under which an
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employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept.
93-807, supra
at 107, 1974-3 C.B. at 342. Section 7476 provides:
SEC. 7476. DECLARATORY JUDGMENTS
RELATING TO…
IRCCourt RulingsAug 24, 1995related by meaning
drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
IRCCourt RulingsSep 15, 2005
…amended by the Consolidated
Appropriations Act, 2001, Pub. L. 106-554, sec. 314(f), 114 Stat.
2763A-643 (2000) to confer jurisdiction to determine "the proper
amount of employment tax."
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IRCCourt RulingsJul 6, 1998
…e sale ($6,114.79).
shares equals $2,471.48 and the amount of gain realized from the
sale equals $3,643.31.
5
Finally, we must decide the character of the gain which must
be recognized from the December 20, 1994, sale. The amount of
the gain attributable to the NUA in the 82 shares of stock at the
time of the distribut…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
IRCCourt RulingsJun 3, 2013related by meaning
T.C. Summary Jpinion 2013-42
UNITED STATES TAX COURT
ASTER TIRF E, Petitioner v.
COMMISSIONER OF INTE 1NAL REVENUE, Respondent
Docket No. 25865-10S. Filed June 3, 2013.
Aster Tirfe, pro se.
Steven Roth, for respondent.
SUMMARlY OPINION
CARLUZZO, Special Trial Judge This case was heard pursuant to the
provisions of sect…
IRCCourt RulingsJun 20, 2001
…INION
COLVIN , Judge
: Respondent determined deficiencies in
petitioner’s Federal income tax of $27,643 for 1994 and $27,024
for 1995, an addition to tax under section 6651(a)(1) of $6,897
for 1994, and accuracy-related penalties under section 6662(a) of
$5,529 for 1994 and $5,330 for 1995.
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1
Respondent determine…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…Accuracy-related penalties
Year Deficiency Sec. 6662(a) Sec. 6662A
2005 $276,032 $55,206 -02006 402,643 80,529 -02007 428,303 -0- $85,660
Netversity, Inc., docket No. 11520-11
Accuracy-related penalty
Year Deficiency Sec. 6662(a)
2006 $9,872 $1,974
2(...continued)
dollar. We interchangeably use the terms "insurance con…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…