IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsJul 24, 1995
…substance or essence of the statute, they must be rigidly observed. Taylor v. Commissioner, 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner, 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather are give…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
… Secretaries and Administrative Assistants
43-6013
27.94
18.13
46.07
Human Resources Specialists
13-1071
49.09
42.74
91.83
Business Operations Specialist
13-1198
59.60
41.72
101.32
General and Operations Manager
11-1021
88.25
34.30
122.55
Compensation and Benefits Manager
11-3111
96.97
24.81
121.78
Computer and Informa…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
… Secretaries and Administrative Assistants
43-6013
18.75
18.75
37.50
Human Resources Specialists
13-1071
33.38
33.38
66.76
Business Operations Specialist
13-1198
38.57
38.57
77.14
General and Operations Manager
11-1021
59.15
59.15
118.30
Compensation and Benefits Manager
11-3111
IRCCourt RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
81 FR 92316 — Claims Procedure for Plans Providing Disability Benefits ERISAFinal Rules (FR)Dec 19, 2016
…rator in the course of making his or her decision.
See Miller
v.
United Welfare Fund, 72 F.3d 1066, 1071 (2d Cir.1995) (compiling cases and stating that “[m]ost circuits have declared that, in reviewing decisions of plan fiduciaries under the arbitrary and capricious standard, district courts may consider only the evid…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsJun 26, 2017related by meaning
t to "a former spouse * * * who is recognized by a domestic
relations order as having a right to receive" a share of the proceeds. See sec.
414(p)(8). Second, the distribution was not made "pursuant to a qualified domestic relations order." Although Jeremy's petition for dissolution of marriage requested a
50-50 divisi…
IRCCourt RulingsAug 24, 1981related by meaning
in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
IRCCourt RulingsJul 31, 2000related by meaning
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
IRCCourt RulingsJan 16, 2020related by meaning
bed in section 72(t) in respect of Mr. Merrell's IRA
distribution is sustained.
As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case.
We have considered similar claims in the past and have observed that there is no
-8au…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
IRCCourt RulingsDec 24, 1985related by meaning
terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange.
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
IRCCourt RulingsJan 2, 2020related by meaning
pute.5
3Respondent determined some itemized deductions should be disallowed
subject to the sec. 68 limitation and a claimed child tax credit should be disallowed under sec. 151(d).
4The sec. 6662(a) penalties for remaining years 2008, 2009, 2010, 2012,
2013, and 2014 stem solely from the disallowed NOL carried forward …
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
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 …
IRCCourt RulingsSep 28, 2022related by meaning
es applicable t o annuity distributions from CRATs. Thus, to
the extent sections 72 and 664 called for different treatment, section 664
would control. Second, section 7 2 do es not call for different treatment. Section
72(b)(1) allows an exclusion from income only to the extent the taxpayer
has an “investment in the co…
IRCCourt RulingsFeb 15, 2002related by meaning
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…