T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner IRCCourt RulingsJan 13, 2005
…er
, 41 T.C. 685,
692-693 (1964), affd. 341 F.2d 290 (4th Cir. 1965); Merker v.
Commissioner
, T.C. Memo. 1997-277; Shaffer v. Commissioner
, T.C.
Memo. 1994-618.
result of his contributions to the plan and that not more than 60
percent of his benefits were attributable to employer
contributions. See Laws v. Commission…
IRCCourt RulingsSep 17, 2009
igher Education,Act of 1965,
20 U .S .C . section 108711, and,claims'deductions based on
estimates in the catalog of the college attended by his son . Section 529 ( e)(3) does not include transportation expenses
as qualified higher education expenses and incorporates section
472 of the Higher Education Act of 1965 only…
IRCCourt RulingsApr 26, 1983
…0 T.C. 619 (1983); Meneguzzo v. Commissioner, 43 T.C. 824, 836 (1965); Davies v. Commissioner, T.C. Memo 1981-438.
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsJan 3, 2017
…tory, creating no
legally enforceable rights for taxpayers. See, e.g., Greene v. Commissioner, T.C.
Memo. 1992-202, 1992 Tax Ct. Memo LEXIS 239; Tucker v. Commissioner, T.C.
Memo. 1983-210, 1983 Tax Ct. Memo LEXIS 578; Chapman v. Commissioner,
T.C. Memo. 1982-68, 1982 Tax Ct. Memo LEXIS 675; see also Marks v.
Commissio…
IRCCourt RulingsDec 11, 2003
… T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, affd. 774
F.2d 426 (11th Cir. 1985).
3
See, e.g., Cavanaugh v. Commissioner
, T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir.
199…
IRCCourt RulingsJul 25, 2012
-285, 2008
Tax Ct. Memo LEXIS 286, at *4. The IRA petitioner inherited from his mother
qualifies as an "inhèrited IRA" under section;408(d)(3)(C)(ii). Rev. Rul. 78-406, r1978-2 C.B. 157, provides that the^direct transfer of funds
from one IRA trustee to a new=IRA trustee which involves no payment or
distribution of fun…
IRCCourt RulingsMay 12, 2000
…es
, 381 U.S.
68, 73-75 (1965); Adler v. Commissioner
, 330 F.2d 91, 93 (9th
Cir. 1964), affg. T.C. Memo. 1963-196; Carter v. Commissioner
, 51
T.C. 932, 935 n.3 (1969). In other words, reliance on an
informal IRS publication may not be used to justify a reporting
position that is inconsistent with the operative law. S…
IRCCourt RulingsDec 17, 1996related by meaning
…e Tax Court Rules of Practice and
Procedure. Dollar amounts are rounded to the nearest dollar.
T.C. Memo. 1996-545
UNITED STATES TAX COURT
CRESTON SWAIM, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20684-94. Filed December 17, 1996.
Creston Swaim, pro se.
Michael D. Zima
, for respondent.
MEM…
IRCCourt RulingsSep 30, 2003related by meaning
…he list
of specific exceptions to tax set forth in section 72(t)(2).
Swihart v. Commissioner
, T.C. Memo. 1998-407. Moreover, unlike
petitioners in the present case, the taxpayers in Larotonda
never
- 8 -
received the funds and had no opportunity to avoid the 10-percent
premature distribution penalty under former secti…
75 FR 42605 — Increase in Tax Rates on Tobacco Products and Cigarette Papers and Tubes; Floor Stocks Tax on Certain Tobacco Products, Cigarette Papers, and Cigarette Tubes; … IRCFinal Rules (FR)Jul 22, 2010related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
IRCRegulationsMay 18, 2016
…ded in the plan ($10,000), or $25,000, does not exceed 25 percent of $125,000. For the taxable year 1965, the X Corporation contributes $140,000 (exclusive of contributions for past service credits) allocated as follows: $100,000 for retirement benefits, $10,000 for life insurance protection, and $30,000 for medical be…
IRCRegulationsSep 17, 2024
…vailing wages under the Davis-Bacon Act (46 Stat. 1494), Public Law 71-798, Service Contract Act of 1965 (79 Stat. 1965), Public Law 89-286, or similar legislation can be taken into account for a plan year for an NHCE to the extent such contributions do not exceed 10 percent of that NHCE's compensation.
IRCRegulationsSep 17, 2024
…prevailing wages under the Davis-Bacon Act (46 Stat. 1494), Pub. L. 71-798, Service Contract Act of 1965 (79 Stat. 1965), Pub. L. 89-286, or similar legislation can be taken into account for a plan year for an NHCE to the extent such contributions do not exceed 10 percent of that NHCE's compensation.
IRCPrivate Letter RulingsMay 4, 2001related by meaning
…30-00/CC:TEGE:EB:QP1
UILC: 4975.07-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area
Attn: Laura Beth Heisen
FROM: Michael Roach, Chief CC:TEGE:EB:QP1
SUBJECT: Adequacy of Department of Labor Notification Pursuant to
I.R.C. §4975(h)…
IRCRegulationsDec 30, 2024
… Y (a fiscal year corporation with a taxable year beginning on July 1, 1964, and ending on June 30, 1965), which stock B sells on October 15, 1964. On December 1, 1964, B purchases all the stock of corporation Z (a fiscal year corporation with a taxable year beginning on September 1, 1964, and ending on August 31, 1965…