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…
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
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).
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…
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 .…
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…
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…
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…
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 …
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…
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
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…
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…
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 …
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…
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…
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 ,…
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…
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…
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…