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88 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    ficiency for the years in issue. Respondent determined that petitioner was liable for additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also determined that petitioner was liable for additions to tax under sections 6651(a)(1) and 6654(a), as set out ab…
  2. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  3. Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U…
    IRCNoticesApr 21, 2014
    …he application (including the retroactive application) of the decision in United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013), and the holdings of Rev. Rul. 2013–17, 2013–38 I.R.B. 201 (Sept. 16, 2013), to retirement plans qualified under section 401(a) of the Internal Revenue Code (Code). SECTION 2. BACKGRO…
  4. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    …tioners’ Federal income taxes for their 1999 and 2000 taxable years in the amounts of $3,347 and $4,570, respectively. The issues for decision are: (1) Whether, pursuant to section 105 1 , 104(a)(3), or 72
  5. Notice 2014-37 — This notice provides guidance on an amendment to reflect the outcome of United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013) that is adopted after th…
    IRCNoticesJun 9, 2014
    …E This notice provides guidance on an amendment to reflect the outcome of United States v. Windsor, 570 U.S. ___, 133 S.Ct. 2675 (2013), that is adopted after the beginning of a plan year and is effective during a plan year (“mid-year amendment”) to a plan described in § 401(k)(12) or (13) (“§ 401(k) safe harbor plan”)…
  6. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  7. Treas. Reg. § 54.4980H-3(d)(6)(vii) — Determining full-time employees.
    IRCRegulationsDec 30, 2016
    …red to credit more than 501 hours of service for the employment break period (15 weeks × 38 hours = 570 hours). Example 4.(i) Facts. Same facts as Example 3, except that Employee B does not resume providing services for Employer Y until December 5, 2015. (ii) Conclusion. Because the period from May 24, 2015 through Dec…
  8. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  9. 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…
  10. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019
    …spondent contended that petitioner is entitled neither to a deduction for the remaining amount, $14,570, of noncash contributions to the donation center and
  11. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010related by meaning
    from qualified retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C . Memo . 2 .005-124 (education expenses paid from a section .401(k)_ plan do not qualify for the exception . of ,section 72(t) (2) (E))- ; Milner v . Commissioner , T .'C .` .Memo . 2004-111 (no "umbrell a hardship exception" .for a distr…
  12. 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…
  13. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005
    … medical expenses in the amount of $18,904, leaving at issue expenses in the amount of $28,666 ($47,570-$18,904). Respondent also concedes that any medical expenses allowed as a deduction under sec. 213 shall be deemed paid for by a portion of petitioner’s withdrawal from his thrift savings plan and are therefore excep…
  14. T.C. Summary Opinion 2017-64 — Wilfred Omoloh v. Commissioner
    IRCCourt RulingsAug 16, 2017related by meaning
    en of proving that those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290 U.S. I11, 115 (1933). I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a qualified retirement plan equal to 10% of the portion of the amount that is includable in gros…
  15. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  16. Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions
    IRCNoticesAug 24, 2026
    …ivalent Saver’s Match contribution in each U.S. territory. The IRS anticipates updating Publication 570, Tax Guide for Individuals with Income from U.S. Territories, to include more detailed information about these funding provisions. 4 Special rules apply to Saver’s Match contributions of less than $100 for a taxable …
  17. 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 …
  18. PLR 201935011 — Year of Deduction
    IRCPrivate Letter RulingsAug 30, 2019
    …rofit sharing plan and trust constituted an “amount paid” within the meaning of § 404(a)(1). Id. at 570. The Court disagreed, stating that “the note, for the maker, even though fully 2 For example, the word “paid” appears twice in the lead-in language of § 404(a). See also paragraphs (a)(1)(A) (“ In the taxable year wh…
  19. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …ust correct the error when brought to the Service’s attention. Buffalow v. United States , 109 F.3d 570, 574 (9 th Cir. 1997). See Tull v. United States , 69 F.3d 394, 399 (9 th Cir. 1995) (Court directed that error be corrected when Service has fail ed to correct designation error). If a taxpayer’s designation, howeve…
  20. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    (c)(2). Thus, we sustain respondent’s determination on this issue. C. Petitioner’s IRA Deductions As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the burden of proving his or her entitlement to the claimed deductions. 18 Rule 142(a)(1); see New Colonial …