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 25, 1996related by meaning
9950-92; W & A Payroll
Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No.
3221-93; W & A Payroll Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No. 10897-93; and Frank A. Pettisani and
Lucille M. Pettisani, docket No. 23719-93.
T.C. Memo. 1996-435
UNITED STATES TAX COURT
BARRY B. BEALOR AND NANCY…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013related by meaning
amended.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590 Continuation coverage
Disclosure
Employee benefit plans
Group health plans
Health care
Health insurance
Medical child support
Reporting and recordkeeping requirements
45…
IRCCourt RulingsAug 13, 1990related by meaning
YE deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)
12/31/80 $1,596 $359 $399
12/31/81 4,263 959 1,066
12/31/82 6,943 1,562 1,389
12/31/83 9,349 2,104 1,309 12/31/84 11,643 2,620 931
12/31/85 14,045 2,528 281
Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $295,956.
Robert H. McCollough
Docke…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
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…
IRCCourt RulingsNov 1, 2005related by meaning
ficiency for the years in
issue. Respondent determined that petitioner was liable for
additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also
determined that petitioner was liable for additions to tax under
sections 6651(a)(1) and 6654(a), as set out ab…
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000related by meaning
d 1992, the years at issue.
2
All section references are to the Internal Revenue Code
(Code) in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
the amount of the reserve described in sec.
419A(c)(2)(A), I.R.C., for post-retirement medical
benefits. Held
, further…
IRCCourt RulingsFeb 18, 1998related by meaning
lure to report any portion of
the distributions. Thus, we find petitioner liable for the
negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock.
In keeping with the above holdings,
Decision will be entered
under Rule 155
.