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85 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…
  2. T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.…
    IRCTreasury DecisionsApr 30, 2007
    …ain plan amendments made pursuant to changes made to section 415 by PFEA and PPA ’06. Under section 101(c) of PFEA (prior to amendment by PPA ’06), a plan amendment to reflect the 5.5 percent interest rate assumption that is generally required to be used for distributions with annuity starting dates in plan years begin…
  3. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  4. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    ot file an income tax return for 2002, respondent asserts that petitioner is liable for an addition to tax under section 6651(a)(1) . Next, respondent asserts that because petitioner failed to file a 2002 tax return, the Secretary filed one on petitioner's behalf pursuant to section 6020(b) ; that a return filed pursua…
  5. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    he Federal Government generally constitute gross income unless excluded by law. Schuller v. Commissioner, T.C. Memo. 2012-347; sec. 1.61-11(a), Income Tax Regs. For a taxpayer who uses the cash receipts and disbursements method of 7 Petitioner's assertion was tried by the consent of the parties. See Rule 41(b). - 7 - a…
  6. 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…
  7. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  8. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  9. T.C. Summary Opinion 2015-60 — Cheryl Lynn Ireland v. Commissioner
    IRCCourt RulingsOct 1, 2015related by meaning
    ioner, 106 T.C. 337, 340 (1996) (citing and discussing the legislative history underlying section 408(f), the statutory predecessor to section 72(t)); Milner v. Commissioner, T.C. Memo. 2004-111. Section 72(t)(2)(B) provides an exception to the imposition of additional tax to the extent that retirement plan distributio…
  10. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    the 1982 plan loan provide no specific repayment date for the $130,000 of principal and require interest to be paid annually at the rate of 15 percent per year. Accordingly, the 1982 plan loan is not a loan described in section 72(p)(2). On the instant record, we reject respondent's argument that section 72(p)(3) disal…
  11. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  12. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …14A(a) does not apply to any qualified CODA established before the date of the enactment of section 101 of the SECURE 2.0 Act (December 29, 2022) or to any annuity contract purchased under a plan established before the date of the enactment of section 101 of the SECURE 2.0 Act. For purposes of this notice, a qualified …
  13. 56 T.C. 1142 — Evans v. Commissioner
    IRCCourt RulingsAug 23, 1971
    101 of the Code provides In part as follows : SEC. 101. CERTAIN DEATH BENEFITS. (a) Proceeds of Life Insurance Contracts Payable by Reason of Death.— (1) Generad rule. — Except as otherwise provided In paragraph (2) and In subsection (d), gross income does not Include amounts received (whether In a single sum or other…
  14. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012related by meaning
    tion of such amount which is includible in gross income." Sec. 72(t)(1). Petitioners state in their petition that the "IRA distributions were used for business support in 2007." Petitioner made no further argument at trial against the imposition of the additional tax. Petitioners' use of the IRA distribution for busine…
  15. 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…
  16. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
    IRCCourt RulingsJun 24, 1966
    of the aforesaid payment [$2,333.33] from claimant’s income under Section 101(b).” Petitioners Bertha and Frieda now argue in their brief as follows: Nothing in Section 101(b) or in respondent’s regulations requires the $6,000 exclusion to be applied with respect to the $7,000 paid in 1960 rather than the $5,000 paid …
  17. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  18. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
  19. 78 FR 13781 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities
    ERISAFinal Rules (FR)Mar 1, 2013
    …set forth in the proposed rules. III. Overview of the Final Regulations A. Amendment of 29 CFR 2520.101-2 Under ERISA Section 101(g). To implement the changes made to ERISA section 101(g) by the Affordable Care Act, these final rules amend the 2003 rule. In the 2003 rule, ECEs and MEWAs were largely subject to the same…
  20. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…