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85 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  2. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011
    … usedein making the determination. Greenberq'á Express, Inc. v. Commissioner, 62 T.C. 324,2 327 '(1-974) . Accordingly, we will' not look into respondèntis .alleged failure to issues a 30-day letter, NId. As to whether the notice of deficiency; is invalid behause it
  3. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987
    …ee also In re Control Systems, Inc., 586 F.2d 1036, 1039 (5th Cir. 1978); In re Kline, 403 F. Supp. 974, 979 (D. Md. 1975), affd. per curiam 547 F.2d 823 (4th Cir. 1977).
  4. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962related by meaning
    3 of reinsurance claimed by petitioner from SNAR is not deductible by petitioner in computing its 1957 net operating loss carry-back to the year 1955. The final issue is whether this Court has jurisdiction with respect to respondent’s claim for increased deficiencies resulting from adjustments contended for by responde…
  5. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    …er value were as follows : As of Death Benefit Net Cash Surrender Valu e 3/1/1999 $595,195 .38 $186,974 .6 8 12/28/1999 4,663,784 .34 220,495 .1 0 12/28/2000 678,528 .13 236,229 .5 7 12/28/2001 688,464 .08 253,038 .0 8 2/5/2003 699,316 .63 272,153 .0 6 3/31/2003 669,547 .00 274,537 .7 2 12/28/2004 713,391 .54 305,930 .…
  6. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
  7. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    IRCCourt RulingsMay 28, 1996
    … Realty Corp. v. Insurance Co. of N. Am. , 34 F.3d 124 (2d Cir. 1994); Johnson v. Hugo's Skateway , 974 F.2d 1408 (4th Cir. 1992). Therefore, the fact that petitioner and respondent met is admissible for the limited - 10 - 5 Despite our holding that petitioner’s objections were abandoned, we note that we did not rely o…
  8. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    etitioner does not cite any relevant law to establish her position. We similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of section 61, that all income is taxable unless explicitly excluded. See Baldwin v. Commissi…
  9. T.C. Memo. 2010-39 — Thomas & Carol Rosato v. Commissioner
    IRCCourt RulingsFeb 25, 2010
    … .C . 225, 232 (1987), affd . 862 F .2d 751 (9th Cir . 1988) ; Simpson v . Commissioner , 64 T .C . 974, 984 (1975) . Relevant factors include : (1) The degree of control exercised by the principal ; (2) which party invests in the work facilities used by the worker ; (3) the opportunity of the individual for profit or …
  10. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    tion that petitioners are liable for the 10-percent additional tax imposed by section 72(t). Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of Additional Tax.--If an…
  11. 77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans
    IRCFinal Rules (FR)Oct 19, 2012
    …: 03/03/14 .015 service: 5 .0175 service: 5 .02 service: 13.5 Average salary: $53,121.00 Total: $22,974.83 Total/month: $1,915.00; deferred Total federal/month ÷ total/month: 0.0 (at time of retirement) Example 7: Disability Occurs After Eligibility for Optional Retirement
  12. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  13. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    …issioner , 404 F.2d 668 (3d Cir. 1968), affg. 48 T.C. 848 (1967); Goodman v. Commissioner , 71 T.C. 974 (1979). jurisdiction. 3 Monge v. Commissioner , 93 T.C. 22 (1989); Yusko v. Commissioner , supra at 807. The phrase "last known address" is not defined in the Internal Revenue Code or the regulations. However, we hav…
  14. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  15. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    …555, respectively, as “Compensation of officers, directors, and trustees” and (2) $156,084 and $264,974, respectively, as “Other deductions”. Respondent made those determinations because the Trust failed to establish that those disallowed amounts constitute expenses directly related to, and therefore deductible from, i…
  16. 84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
    IRCFinal Rules (FR)Jun 20, 2019
    …415 697,476 33,594 2022 3,008 477,859 9,024 1,162,461 65,945 3 year average 2,005 273,492 6,016 774,974 37,742 The burden related to these ICRs will be reviewed under emergency review and approval. They have been submitted to OMB in conjunction with this final rule and are pending approval. 4. ICRs Regarding Notice Req…
  17. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    …d a n updated Form 433 – B , dated May 5, 2023, that reflected net equity in assets totaling $2,442,974 . The updated form also reflected that MDIA had average gross monthly business income of $741,887 (compris ing $ 741,795 of gross receipts and $92 of dividends) , average gross monthly business expenses of $680,105 ,…
  18. 70 T.C. 24 — Keeler v. Commissioner
    IRCCourt RulingsApr 17, 1978
    …. Under the terms of the plan the petitioner received a lump-sum distribution in the amount of $230,974 during the year 1973. Pursuant to section 402(a)(2) of the Code, $219,632 of the lump-sum distribution received by petitioner in 1973 qualified for treatment as long-term capital gain and was so reported by petitione…
  19. IRCCourt RulingsJun 13, 1977
    … stand in an employer-employee relationship is a factual question. Simpson v. Commissioner, 64 T.C. 974, 984 (1975); Ellison v. Commissioner, 55 T.C. 142, 152 (1970); James v. Commissioner, 25 T.C. 1296, 1300 (1956); Hand v. Commissioner, 16 T.C. 1410, 1414 (1951). Section 31.3121(d)-l(c)(2), Employment Tax Regs., prov…
  20. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    ciency in excise tax under section 4973 on the basis of a determination that the taxpayers had made excess contri butions to their IRAs. The taxpayers urged that they had no excise tax liability because the IRS had not 6 See United States v. Skelly Oil Co. , 394 U.S. 678, 684 (1969); ATL & Sons Holdings, Inc. v. Commis…