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82 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. PLR 201628006 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …. 666, 673 (1990) ; Fono v. Commissioner, 79 T.C. 680, 695 (1982) , affd. without published opinion 749 F.2d 37 (9th Cir. 1984) ; American Nur seryman Publishing Co. v. Commissioner, 75 T.C. 271, 275 (1980) , affd. without published opinion 673 F.2d 1333 (7th Cir. 1981) . . . . Wh ile we will look to local law in order…
  2. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    …r section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imposed by section 7491(c) . -20Accordingly, petitioners bear the burden of proving tha t respondent's determin…
  3. PLR 201628005 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …. 666, 673 (1990) ; Fono v. Commissioner, 79 T.C. 680, 695 (1982) , affd. without published opinion 749 F.2d 37 (9th Cir. 1984) ; American Nurseryman Publishing Co. v. Commissioner, 75 T.C. 271, 275 (1980) , affd. without published opinion 673 F.2d 1333 (7th Cir. 1981) . . . . Wh ile we will look to local law in order …
  4. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …ransaction. See sec. 1.6664-4(c)(i), Income Tax Regs.; see also Leonhart v. Commissioner , 414 F.2d 749 (4th Cir. 1969), affg. T.C. Memo. 1968-98. Reliance may be unreasonable when it is placed upon insiders, promoters, or their offering materials, or when the person relied upon has an inherent conflict of interest
  5. T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 17, 1998
    … Cir. 1997), revg. and remanding 102 T.C. 760 (1994); Estate of Vissering v. Commissioner , 96 T.C. 749, 755-756 (1991) ("It is virtually hornbook law that State law determines the legal interests and rights created by a trust instrument, while Federal law determines the Federal tax consequences of those interests and …
  6. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  7. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    … Mr. Larson’s distributive share of Morley income, resulting in defic iencies of $6,867,653, $2,431,749, and $1,253,344 for the 1999, 2000, and 2001 tax years, respectively. The first issue for decision is whether respondent erred in determining that Mr. Larson’s stock in
  8. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …me it received from the Delphi contract or any gross receipts. It reported total deductions of $273,749, including travel expenses of $139,323, meals and entertainment expenses of $11,898, and a small amount of cancellation of indebtedness income, for a net loss of $271,853. As sole shareholder, petitioner reported Str…
  9. T.C. Memo. 2005-133 — Gloria Yuen-Mee Ho & Alexander Chi-Shun Tsang v. Commissioner
    IRCCourt RulingsJun 2, 2005
    …Court does not have jurisdiction over matters involving interest. Perkins v. Commissioner , 92 T.C. 749, 752 (1989). None of the exceptions to this rule apply in these cases. See, e.g., sec. 7481(c); see also sec. 6404(h). We have considered all of the remaining arguments that have been made by petitioners for a result…
  10. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  11. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    ax of $3,000.60 because she received.the distributions before she attained age 59-1/2 and the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v). Discussion Summary judgment is intended to.expedite litigation and avoid unnecessary and expensive trials and may be granted where the…
  12. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …ed March 15, 1993, shows a balance forward of $734, other charges of $15, and an ending balance of $749. Petitioner has only established that he charged uniforms in the amount of $217. Petitioner testified that he paid the balance on his account by the end of 1993 because he stopped working for Delta at that time. Base…
  13. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  14. 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…
  15. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  16. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  17. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    …tates, 434 U.S. 528, 533, 98 S.Ct. 841, 845, 55 L.Ed.2d 1 (1978); Bingler v. Johnson, 394 U.S. 741, 749-751, 89 S.Ct. 1439, 1444-1445, 22 L.Ed.2d 695 (1969). * * * [Commissioner v. Portland Cement Co. of Utah, 450 U.S. 156, 169 (1981).]
  18. 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 …
  19. T.C. Memo. 2004-287 — Michael J. Barkley v. Commissioner
    IRCCourt RulingsDec 28, 2004
    …tribution in gross income. Petitioner also reported that he owed an additional 10percent tax of $14,749 for receiving an early distribution from the plan. - 6 - 4 Petitioner’s petition was mailed on Apr. 13, 2002. On April 22, 2002, petitioner’s petition in this case was filed. 4 On September 1, 2002, petitioner and Mr…
  20. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995
    …general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975); see sec. 6404(e); Marine v. Commissioner , 92 T.C. 958, 994 (1989), affd. without published opinion 921 F.2d 280 (9th Cir. 1991); 508 Clinton St. Corp…