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84 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 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-…
  2. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962related by meaning
    because in the opinion of the Canadian counsel, petitioner had no claim recognizable under Canadian law and to proceed with the suit would be costly. In July 1958 petitioner, through its counsel, engaged a French attorney to attempt to recover, through the liquidator of SNAB in France. Later in 1958 the French attorne…
  3. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    w why the statute as enacted contains language different from that in the House and - 10 - 1 We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize this Court to grant a declaratory judgment include secs. 6234, 7428, 7477, 7478, and 7479. 2 Sec. 7503 a…
  4. T.C. Summary Opinion 2015-37 — Charles D. Trainito v. Commissioner
    IRCCourt RulingsJun 23, 2015
    …f $22,510.97 from the retirement board, which represents a gross distribution of $28,138.21 less $5,627.24 in Federal income tax withheld. There are no facts in evidence about the use to which petitioner applied these proceeds. Petitioner filed a Form 1040, U.S. Individual Income Tax Return, for tax year 2011 on Novemb…
  5. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  6. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
    IRCCourt RulingsJul 29, 2003
    …etitioner’s document for 1996 is not a valid tax return for that year. See United States v. Moore , 627 F.2d 830, 834 (7th Cir. 1980); Williams v. Commissioner , 114 T.C. 136, 139140 (2000); Sloan v. Commissioner , 102 T.C. 137, 143 (1994), affd. 53 F.3d 799 (7th Cir. 1995); Cupp v. Commissioner , 65 T.C. 68, 78-79 (19…
  7. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    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 …
  8. T.C. Summary Opinion 2004-100 — Kurt Steven & Juanita Fay Urban v. Commissioner
    IRCCourt RulingsJul 27, 2004
    …transaction or particular privilege of selling real property. In - 9 - Mahler v. Tremper , 243 P.2d 627, 629-630 (Wash. 1952), the Supreme Court of the State of Washington held that a county tax on the sale of real estate is an excise tax and not a property tax because it is a tax on the transaction rather than merely …
  9. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    T.C. Summary Opinion 2013-96 UNITED STATES TAX COURT SAMUEL BRACH AND LILLIAN BRACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15460-12S. Filed December 2, 2013. Ronald Jay Cohen, for petitioners. Gennady Zilberman, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was h…
  10. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …ndividual decedent and his estate or beneficiaries.'" Estate of Smith v. United States, 391 F.3d at 627. (quoting Estate of Robinson v. Commissioner, 69 T.C. 222, 225 (1977)). Further, the Court of Appeals determined that the estate failed to recognize that "the willing buyer-willing seller test is an objective one * *…
  11. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
  12. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …nts estimate that 1,579 health insurance issuers and 184 TPAs would incur a one-time hour burden of 627 hours and an associated cost of $55,257 to fully satisfy the requirements of these proposed rules. For all 1,763 health insurance issuers and TPAs, the total one-time hour burden would be 1,105,464 hours with an equi…
  13. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  14. 67 T.C. 411; 1 Employee Benefits Cas. (BNA) 2232 — Hill, Farrer & Burrill v. Commissioner
    IRCCourt RulingsDec 14, 1976
    … he receives under the plan until the year in which he receives it. Ronald C. Packard, 63 T.C. 621, 627 (1975). Prior to 1962, however, a partner who performed services for his partnership was not considered an employee for the purposes of those provisions, with the results that the partnership was not entitled to a de…
  15. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …unt indicated in the right column. Paragraph Remove Add § 100.4(a) $2,277 $2,314 § 100.4(b) 4,553 4,627 § 100.4(c) introductory text 5,692 5,785 § 100.4(c) introductory text 68,300 69,417 § 100.5(c) 7,399 7,520 § 100.5(d) 313 318 § 100.5(e) 250,433 254,530 ( printed page 5384) Note:
  16. T.C. Memo. 2013-124 — Kenneth A. Carter, Robert J. Kurek, John McFawn, Paul L. Miles, Adolph F. Rivas, Curlee Thomas, and Q.C. Williams, Jr.; Petitioners v. Commissioner of Internal…
    IRCCourt RulingsMay 9, 2013
    …T.C. 235, 240 (1997) (citing Montana, 440 U.S. at 153-154, and United States v. ITT Rayonier, Inc., 627 F.2d 996, 1000 (9th Cir. 1980)). "Collateral estoppel may be utilized in connection with matters of law, matters of fact, and mixed matters of law and fact." Meier v. Commissioner, 91 T.C. 273, 283 (1988). The Commis…
  17. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  18. 89 T.C. 225; 89 T.C. No. 19 — Professional & Executive Leasing v. Commissioner
    IRCCourt RulingsAug 3, 1987
    …ee and direct every move that he makes” (Atlantic Coast Life Ins. Co. v. United States, 76 F. Supp. 627, 630 (E.D. S.C. 1948); Simpson v. Commissioner, supra at 985), and that an employer’s control over the manner in which professional employees conduct the duties of their positions “must necessarily be more tenuous an…
  19. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  20. 76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests
    IRCFinal Rules (FR)Aug 10, 2011
    … for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 7.627% (8% × .953317). Based on the remainder factors in Table U(1) in this section, the present value of the remainder interest is $11,075.00, computed as follows: * * * * * (7) Actuarial Table U(1) for transfers for whic…