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79 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  2. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    ec. 6662(d). Here the understatement of $6,949 is substantial because it exceeds $5,000 and is greater than 10% of the tax required to be shown on the return. Consequently, respondent has carried his burden of production. As a result, petitioners now bear the burden to show that an exception to the penalty applies. See…
  3. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    Atkins, Judge: The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…
  4. 102 T.C. 499; 102 T.C. No. 17 — Janpol v. Commissioner
    IRCCourt RulingsMar 28, 1994
    … of willful neglect in failing to file the Form 1120 returns as required by the regulations. Id. at 795.
  5. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  6. 89 FR 58886 — Required Minimum Distributions
    IRCFinal Rules (FR)Jul 19, 2024
    …ve the remaining distributions from Plan W in the form of an immediate final lump sum payment of $2,795,732. Because payment of retirement benefits in the form of an immediate final lump sum payment satisfies (in terms of form) section 401(a)(9), the condition under paragraph (n)(3)(i) of this section is met. (B) Analy…
  7. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    _ requirements under section 6020(b) Wheeler v. Commissioner, 127 T.C. 200 208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). A return made by the Secretary under section 6020(b) is'treated as the return filed by the taxpayer for purposes of section 6651(a)(2). Sec. 6651(g)(2). Respondent'satisfied his burden by in…
  8. T.C. Memo. 2003-294 — Randolph S. Simpson, I v. Commissioner
    IRCCourt RulingsOct 21, 2003
    …ion 71 was amended by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 422(a), 98 Stat. 494, 795, to establish an objective standard to distinguish between a payment received in the division of property (which is not includable in gross income) and a payment received as spousal support (which is
  9. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  10. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998
    …ital 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 under the specific instruction in section 7476(b)(1) that a person who wishes to be an employee party-…
  11. 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…
  12. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989related by meaning
    nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
  13. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    Federal income tax return on or before the payment due date unless such failure is due to reasonable cause and not due to willful neglect. The section 6651(a)(2) addition to tax applies only when an amount of tax is shown on a return filed by the taxpayer or prepared by the Secretary. Sec. 6651(a)(2), (g)(2); Cabirac v…
  14. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  15. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …726.302(c)(5) $402 $409. § 726.302(c)(6) August 1, 2016 January 13, 2017. § 726.302(c)(6) $2,750 $2,795. Department of Labor Wage and Hour Division Title 29—Labor PART 500—MIGRANT AND SEASONAL AGRICULTURAL WORKER PROTECTION 9. The authority citation for part 500 continues to read as follows: Authority: Pub. L. 97-470, …
  16. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
    IRCCourt RulingsMay 17, 1973related by meaning
    was “earned income” within the ambit of section 911 (b) and is excludable from gross income to the extent of $25,000 per year under section 911 ('a). Petitioner has claimed overpayments of $5,517 for 1965 and $7,040.82 for 1966. As to the first amount, it is stipulated that the petitioner overstated his gross income f…
  17. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015
    …Initially, Annually, When engaging in exempted transaction. Estimated Total Annual Burden Hours: 28,795 hours. Estimated Total Annual Burden Cost: $782,647. General Information The attention of interested persons is directed to the following:
  18. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981
    …ssioner determined deficiencies in the petitioners’ Federal income taxes of $1,850.54 for 1975 and $795.58 for 1976. Also, for 1975, he determined an addition to tax under section 6653(a) of the Internal Revenue Code of 1954 of $92.53. After concessions by the petitioners, the issues for decision are: (1) Whether in 19…
  19. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  20. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004related by meaning
    is liable for the second-tier excise tax under section 4975(b). We note, however, - 19 - that sections 4961(a) and 4963(e)(1) generally allow for the abatement of a second-tier excise tax if the prohibited transaction giving rise thereto is corrected within 90 days after our decision sustaining the tax becomes final. …