IRCCourt RulingsNov 4, 1998related by meaning
laration shall have the force and effect of a
decision of the Tax Court and shall be reviewable as
such. For purposes of this section, a determination with respect to a continuing qualification includes any
revocation of or other change in a qualification.
(b) Limitations.--
(1) Petitioner.--A pleading may be filed und…
IRCCourt RulingsOct 11, 1957
…rent in character from other types of property. As was said in Bailey v. United States, 27 F. Supp. 617, 627 (Ct. Cl., 1939):
Life insurance is inherently testamentary in character. The payment of premiums and the insured’s death are the necessary events giving rise to the full and complete possession and enjoyment of …
IRCCourt RulingsFeb 22, 1999related by meaning
lating to petitioners' loan,
10.5 percent is the fair market interest rate.
V. Addition to Tax
Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to
file Form 5330 for each taxable year, or portion thereof, in the
taxable period. Sec. 6011; sec. 54.6011-1(…
IRCCourt RulingsApr 24, 2017
…e.g., Culp v.
Commissioner, T.C. Memo. 1989-517; see also Mitchell v. Commissioner, T.C.
Memo. 1990-617, aff'd without published opinion, 992 F.2d 1219 (9th Cir. 1993).
T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 17, 1998
…(West 1984); see also Wagner
v. Hart Chem. Co.
, 597 A.2d 1208 (Pa. Super. Ct. 1991),
alloc. denied 617 A.2d 1275 (Pa. 1992). As applied to the
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taxable year in issue, section 8313(a) of the Pennsylvania
Commercial Code provides:
Delivery to a purchaser occurs when:
(1) he or a person designated by him acquires
p…
IRCCourt RulingsJan 26, 2006
…13, 60 (1995), affd. 140 F.3d 240 (4th Cir. 1998); Estate of
Emerson v. Commissioner
, 67 T.C. 612, 617-618 (1977); Megibow v.
Commissioner
, T.C. Memo. 2004-41; see also Lignos v. United
States
, 439 F.2d 1365, 1368 (2d Cir. 1971).
The IRS employee made a mistake of law by including only
$1,532 as the taxable portion …
IRCCourt RulingsOct 28, 1997
…ductions for expenses as follows:
Advertising $340
Auto and travel 1,710
Cleaning and maintenance 2,617
Insurance 2,602
Legal and other professional fees 127
Mortgage interest 27,263
Repairs 4,896
Supplies 78
Taxes 13,780
Utilities 1,721
Total $55,134
Thus petitioner claimed a loss of $33,139 from rental real
estate. P…
T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov… IRCTreasury DecisionsAug 15, 2016related by meaning
ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred.
EMPLOYEE PLANS
T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
IRCCourt RulingsAug 16, 2005
…bts and home mortgage which
were paid by the above checks.
- 6 -
From the record, the remaining $57,617.93, which was
deposited into the joint savings and checking accounts, was not
readily traceable. However, on November 28, 2001, the balance in
the joint savings account was $57,878.32.
As stated previously, petitione…
IRCCourt RulingsJan 2, 2020related by meaning
n 72(t) imposes an additional 10% tax on early distributions from a
qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not
attained the age of 59½ when she received the distributions at issue. The IRA
distribution…
IRCCourt RulingsApr 2, 2024
…a postponement of the period to file a petition with this Court.
See Stone v. Commissioner, 73 T.C. 617, 620– 21 (1980) (“Section
7508(a)(1)(C) excludes the period du ring which a member of the Armed
Forces is present in a ‘combat zone’ in determining the time allowable
for the filing of a petition with the Tax Court f…
IRCCourt RulingsOct 9, 1997
…ded November 30, 1986, if
based on the safe harbor limits of section 419A(c), is
$10,020,825 (plus $617,245 of related administrative costs), and
if not based on the safe harbor limits, is $7,619,925 (plus
$395,683 of related administrative costs). The parties also
stipulated an increase, pursuant to section 419A(f)(7)…
IRCCourt RulingsAug 16, 2005
…ard debts and home mortgage which
were paid by the above checks.
From the record, the remaining $57,617.93, which was
deposited into the joint savings and checking accounts, was not
readily traceable. However, on November 28, 2001, the balance in
the joint savings account was $57,878.32.
As stated previously, petitione…
IRCCourt RulingsFeb 6, 1992related by meaning
n is subject to section 404. It is difficult, if not impossible, to discuss deferring receipt of compensation without focusing on the time of payment. We also reject petitioner's contention that the case at hand is similar to that in Minahan v. Commissioner, 88 T.C. 492 (1987). We held, in that case, that the Secretary…
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 RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsMar 31, 1997
…499 of which is
in dispute in the instant case (the 1987 Vacation Pay).
Petitioner deducted $62,841,617 attributable to its vacation pay
liability on its return for TYE 8801, $17,927,808 of which
remains in dispute (the 1988 Vacation Pay).
A. The Terms of the Vacation Benefits Plans
Petitioner provided vacation pay ben…
IRCCourt RulingsDec 14, 2009
… k
rapidly . The insurance policy had net cash surrender values of
$78,293 .21 on May 28, 2000, $55,617 .96 on May 28, 2001,
$33,357 .02 on May 28, 2002, and $12,703 .22 on May 28, 2003 . By
November 28, 2003, the monthly statement had indicated that the
net cash surrender value had been diminished to $2,782 .25 .
On M…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…closure
108,000
108,000
108,000
108,000
Investment Disclosure Total
8,390,000
1,230,000
1,230,000
3,617,000
Request for Additional Information for Exemption
19,000
9,000
9,000
13,000
Notice to DOL
2000
900
900
1,000
Total
8,830,000
1,435,000