IRCCourt RulingsJun 9, 2009
…g on a trade or business . See commissioner v . Lincol n
Sav . & Loan Association , 403 U .S . 345, 352 (1971) . In ordler fo r
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…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
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…
IRCCourt RulingsJul 9, 1997
…a)
Addition
to Tax
Sec. 6654
1987 $ 5,515 ($1,693) $ 0 $ 0
1988 5,366 (4,952) 0
1990 12,328 5,409 1,352 305
1991 2,321 (718) 0 0
1992 4,114 1,551 388 55
Petitioners concede that the overpayments are barred by section
6511(b)(2)(B).
We must decide the following issues:
(1) Whether petitioners are required to include, as…
IRCCourt RulingsMay 15, 2003
… Inc. (ATI) and
remains currently employed there. Mr. Keeley earned $3,115 with
ATI in 1997 and $44,352 in 1998.
In 1998, Mr. Keeley withdrew the remaining IRA balance at
National in the amount of $5,280. Mrs. Keeley also withdrew the
balance of her Illinois Municipal Retirement Fund
5
(pension) in
the amount of $2,998…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
453,647 821,352 958,237 1,335,044
L. Account limit (yearend)
5
8,701,773 15,781,474 25,514,292 36,161,092
M. Actual contribution 30,689,717 2,170,000 13,966,816 12,247,933
N. Value of assets (yearend) 30,736,554 30,176,217 39,940,67…
IRCCourt RulingsJul 31, 2000
…d (5) was an ordinary expense. See Commissioner v. Lincoln Savs. &
Loan Association
, 403 U.S. 345, 352 (1971); Welch v. Helvering
,
290 U.S. 111, 115 (1933). A determination of whether an
expenditure satisfies each of these requirements is a question of
fact. See Commissioner v. Heininger
, 320 U.S. 467, 475 (1943).
P…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsNov 3, 2008
…rade .or business for purposes of section 162(a) .
6 - , O'Malley v . Commissioner , :91 T : .C . . 352, 363-364 .(1988) . However ; .
if an employee's expenses are,reimbursable by his or .her
employer, those expenses are .not-necessary„and cannot be
deducted . Orvis v . Commissioner , 788,F .2d 14`06, 1408 .(,9th Cir …
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsJul 2, 2002
…dated,
the rate was 6.81 percent. See Rev. Rul. 90-1, 1990-1 C.B. 155;
Rev. Rul. 91-41, 1991-2 C.B. 352.
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
IRCCourt RulingsJul 30, 1985related by meaning
Eanes as petitioner.
In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
IRCCourt RulingsSep 21, 2017
…50, 255 (1998); Gallagher v. Commissioner, T.C. Memo. 200134; Deal v. Commissioner, T.C. Memo. 1999-352.
Petitioners do not dispute that the distributions in 2013 and 2014 of $83,480
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
80 FR 22004 — Proposed Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Em… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
to Citation
11.
See
Preamble to PTE 75-1, Part V, 40 FR 50845 (Oct. 31, 1975); ERISA Advisory Opinion 86-12A (March 19, 1986).
Back to Citation
12. Because of this limitation, the Department views it as unnecessary to condition this exemption on the fiduciary's adherence to the impartial conduct standards, including…
IRCCourt RulingsAug 8, 1996
…ee Commissioner v. McCoy
, 484 U.S. 3, 7
(1987); 508 Clinton Street Corp. v. Commissioner
, 89 T.C. 352,
354 (1987).
Decision will be entered for
respondent with respect to the
deficiency, including the
additional tax under sec. 72(t),
and decision will be entered for
petitioners with respect to the
penalty under sec. …
IRCCourt RulingsFeb 26, 1964related by meaning
kly pay period, the Secretary or his delegate shall by regulations prescribe the method of determining the weekly rate at which such amounts are paid. (e) Accident and Health Plans. — For purposes of this section and section 104—
(1) amounts received under an accident or health plan for employees, and
(2) amounts recei…