IRCCourt RulingsMar 5, 2018related by meaning
r I.R.C. sec. 4973.
He] : On the facts presented, Ps and not their Roth IRAs were
the owners, for Federal tax purposes, of the FSC stock; in substance the FSC dividends were income to Ps, who contributed the funds to
their Roth IRAs. Summa Holdings, Inc. v. Commissioner, 848 F.3d
779 (6th Cir. 2017), rev'g T.C. Memo. 2…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
IRCCourt RulingsJun 3, 2013related by meaning
T.C. Summary Jpinion 2013-42
UNITED STATES TAX COURT
ASTER TIRF E, Petitioner v.
COMMISSIONER OF INTE 1NAL REVENUE, Respondent
Docket No. 25865-10S. Filed June 3, 2013.
Aster Tirfe, pro se.
Steven Roth, for respondent.
SUMMARlY OPINION
CARLUZZO, Special Trial Judge This case was heard pursuant to the
provisions of sect…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
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(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsJul 26, 2007related by meaning
sioner , T .C . Memo . 2001-34 .
We recognize that petitioner received his IRA distribution
at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable
purpose . Unfortunately for petitioner, we are bound by the lis t
of statutory exceptions set forth in sectio…
83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCProposed Rules (FR)Proposed Oct 29, 2018
…insurance coverage, provided all the conditions in 29 CFR 2510.3-1(l) are satisfied.
* * * * * PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
17. The authority citation for part 146 continues to read as follows:
Authority:
42 U.S.C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92…
IRCCourt RulingsSep 30, 2003related by meaning
t for payment of an assessed
deficiency and the bank trustee paid the money directly to the
IRS. Former section 72(m)(5) differed from current section 72(t), particularly in that the former did not include the list
of specific exceptions to tax set forth in section 72(t)(2).
Swihart v. Commissioner
, T.C. Memo. 1998-40…
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…
IRCFinal Rules (FR)Aug 3, 2018
…s and their applicability to other people or circumstances shall continue in effect.
* * * * *
PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET
9. The authority citation for part 146 is revised to read as follows:
Authority:
42 U.S.C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92…
IRCCourt RulingsDec 13, 2012related by meaning
CLC
T.C. Memo. 2012-344
UNITED STATES TAX COURT
KARL E. CROSS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6009-09. Filed December 13, 2012.
Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner.
Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent.
MEMORANDUM OPIN…
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 …
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsJul 11, 2024related by meaning
y
Congress. See § 7442 ; Naftel v. Commissioner, 85 T.C. 527, 529 ( 1985) .
In a deficiency case , our jurisdiction is predicated on a valid notice of deficiency and a timely filed petition . See §§ 621 2 – 6214; Dees v.
Commissioner, 148 T.C. 1, 3 – 4 (2017) ; see also Sanders v. Commissioner,
9
[* 9 ] No. 15143-22, 1…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
IRCCourt RulingsJun 7, 1984related by meaning
eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
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 -
[…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
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 …