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89 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2009-133 — Paul Rudnick v. Commissioner
    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
  2. 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…
  3. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    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…
  4. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    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…
  5. 74 T.C. 651 — Judd v. Commissioner
    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…
  6. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    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…
  7. T.C. Summary Opinion 2003-53 — Brian P. & Mary G. Keeley v. Commissioner
    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…
  8. 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…
  9. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
  10. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  11. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    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 …
  12. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    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…
  13. T.C. Memo. 2002-166 — Wayne A. McFadden v. Commissioner
    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.
  14. 74 T.C. 1057 — Johnson v. Commissioner
    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…
  15. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    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…
  16. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    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
  17. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  18. 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…
  19. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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. …
  20. 41 T.C. 685 — Conroy v. Commissioner
    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…