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…
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…
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 -
[…
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…
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…
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…
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)…
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.
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…
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…
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):
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…
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…
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 …
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…
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…