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56 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    402(c)(3)(B). See SERVED Apr 20 2017 - 2 - Rev. Proc. 2003-16, 2003-1 C.B. 359, as modified retrospectively by Rev. Proc. 2016-47, 2016-37 I.R.B. 346. Ideld, further, the Tax Court has jurisdiction in this deficiency proceeding to review R's denial of Ps' request for a waiver of the 60day rollover requirement. Held, fu…
  2. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68 (3d Cir…
  3. 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 - […
  4. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    tion that petitioners are liable for the 10-percent additional tax imposed by section 72(t). Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of Additional Tax.--If an…
  5. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  6. T.C. Memo. 1996-146 — Lloyd Patterson v. Commissioner
    IRCCourt RulingsMar 25, 1996related by meaning
    …er did not engage in his apartment house activity in 1991 for profit within the meaning of sections 162, 212, or 183. We turn to section 183(b) which provides in pertinent part that in the case of an activity which is not for profit, the deductions allowable are those allowable "without regard to whether or not such ac…
  7. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  8. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  9. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    ts, with the terms of imprisonment to run concurrently for a total of 38 months' imprisonment. Among the accounts forfeited were petitioner's IRA's at Merrill Lynch and Fidelity Investments (the IRA's). The total amount forfeited from the IRA's (the IRA distributions) was $230,161. Petitioner was 57 years old at the ti…
  10. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  11. 63 T.C. 267 — Cohen v. Commissioner
    IRCCourt RulingsNov 26, 1974related by meaning
    o him under the provisions of section 165(b), I.R.C. 1939, which contained provisions comparable to those of section 402(a), until distributed to him. In the Megibow case we stated in part (21 T.C. at 199-200):
  12. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    , after holding that the taxpayer had no unpaid income tax for that year) ; Rowe v . Commissioner , T .C . Memo . 2001-325 (holding that the Court has jurisdiction to review the Commissioner's denial of section 6015(f) relief from additions to tax and penalties) . We hold that "taxes" in TRHCA section 408(c) includes t…
  13. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  14. T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner
    IRCCourt RulingsJan 19, 2016related by meaning
    d the earlier of the Participant's life expectancy * * *. * * * * * * * 11.2 ALIENATION (a) Subject to the exceptions provided below, and as otherwise permitted by the Code and Act, no benefit which shall be payable out of the Trust Fund to any person (including a Participant or the Participant's Beneficiary) shall be …
  15. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    ................................. 9 MIT 80.................................................. 12 Formation of MIT 80................................ 12 Investors in MIT 80................................ 13 Organization and Management of MIT 80.............. 13 MIT 80 Employee Leasing Arrangement................ 14 Oper…
  16. 161 T.C. No. 6 — Estate of James E. Caan, Deceased, Jacaan Administrative Trust, Scott Caan, Trustee, Special Administrator v. Commissioner
    IRCCourt RulingsNov 14, 2023related by meaning
    efit of his employees or their beneficiaries.” I.R.C. § 401(a). 27 The IRS summarily denied the request in a boilerplate response. See id. at 338– 39. In deciding that we had jurisdiction to review the IRS’s denial of a hardship waiver under section 402(c)(3)(B), we stated: Nothing in section 402(c)(3) expressly preclu…