IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsJun 3, 1998
…competent, independent tax professional. See
- 30 -
sec. 6664(c); Freytag v. Commissioner
, 89 T.C. 849, 888
(1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501
U.S. 868 (1991); sec. 1.6664-4(b)(1), Income Tax Regs.
Such reliance is not an absolute defense to negligence
but merely a factor to be considered. See Frey…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
arding
enforceable claims of the parties; and (ii) the parties'
assessments
of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable
outcomes under the governing instruments and applicable State law.
Therefore, based …
T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner IRCCourt RulingsApr 22, 1998
…gues that the recent Supreme Court
decision in United States v. Brockamp
, 519 U.S. ___, 117 S. Ct.
849 (1997), questions the continued viability of the duty of
consistency as equitable relief in the Tax Court.
- 6 -
3
Petitioner argues that the decision by the Court of
Appeals for the Ninth Circuit to apply the duty o…
IRCCourt RulingsMar 6, 2001
…titioner earned no self-employment income. During
1976 and 1977, respectively, petitioner earned $4,849 and $1,059
in net self-employment income from sales of Fidelity insurance
products. Petitioner had no self-employment income for the 1989
tax year. For the 1990 and 1991 tax years, petitioner reported
- 34 -
net loss…
IRCCourt RulingsMar 3, 1997related by meaning
fd. without
published opinion 998 F.2d 1018 (8th Cir. 1993).
Based on the foregoing, respondent's determination is
sustained.
Decision will be entered for respondent
.
IRCCourt RulingsApr 3, 2023
…notice of deficiency is unsupported by any
significant evidence. Schaffer v. Commissioner, 779 F.2d 849, 858 (2d
Cir. 1985), aff’g in part , remanding in part Mandina v. Commissioner,
T.C. Memo. 1982-34. Once the Commissioner makes the required
threshold showing, the burden shifts to the taxpayer to prove by a
preponde…
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
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 RulingsSep 19, 1978
…as to 1970, 1971, and 1973. Cf. Christian Echoes National Ministry, Inc. v. United States, 470 F.2d 849, 858 (10th Cir. 1972).
IRCCourt RulingsMay 21, 1999
…
Legal & professional services 655
Office expense 1,485
Travel 2,156
Other expenses:
Beeper, phone $849
Subscriptions & law books 974
Clothing, shoes & maintenance 728
Seminars 593
Continuous legal education
& examination fees 1,935
5,079
Total
14,897
Schedule C: "Clothing And Accessories"
Cost of goods sold $3,128
Exp…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…er disclosures annually. This results in an estimated cost of approximately $20.1 million annually.[849]
Costs Associated With the Provision of Disclosures to Retirement Investors
The Department estimates that the number of disclosures that will need to be provided to Retirement Investors by small entities is equal to …
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …
IRCCourt RulingsJan 29, 2019
…h location. According to the mileage logs, petitioner
drove a total of 28,752 business miles and 11,849 business miles in 2009 and
2010, respectively, for his business, less than the figures reported on the Forms
2106-EZ for both years.
Furthermore, petitioner's mileage logs are also contradicted by a
maintenance repor…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…18,923 small plans) and 8,475 health or welfare plans (5,626 large plans filing a schedule H, and 2,849 small plans filing a schedule I).[111]
IRCCourt RulingsJan 3, 2017
…inally, petitioner reported Federal income tax withheld of $8,9685 and
claimed an overpayment of $4,849, which was refunded to her in May 2012.
On June 3, 2013, respondent's Automated Underreporter (AUR) function
sent petitioner a Notice CP2000 proposing changes to the 2011 return on the basis
that certain income and p…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…ling Plan. The
Tomassettis reported taxable income of $357,456 and total Federal income tax of
$112,849.
The Tomassettis filed a 2007 Form 1040X. The 2007 amended return did
not reflect any change related to Mr. Tomassetti's participation in the Sterling
Plan.
G. Deficiency Notices
On March 2, 2011, respondent mailed d…
IRCCourt RulingsApr 30, 2003related by meaning
dvice. Sec.
6404(f).
owed for 1999 was "none" should mean that she does not owe any
additional tax.
Respondent concedes that $10,000 of the money that petitioner used to buy a house qualifies under section
72(t)(2)(F) and (8)(B) for exclusion from the additional tax on
early distributions from a qualified retirement pl…
85 FR 81658 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAFinal Rules (FR)Dec 16, 2020
…29,396 small plans) and 8,475 health or welfare plans (5,626 large plans filing a schedule H, and 2,849 small plans filing a schedule I).[121]
IRCCourt RulingsMay 19, 2011
… not an
"absolute defense" but merely "a factor to be considered."
Freytag v. Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d
1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991). Whether
reasonable cause exists when a taxpayer has relied on a tax
professional to prepare a return must be determined on the basis
of all…