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60 documents · 0.30sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  2. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  3. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  4. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-244 UNITED STATES TAX COURT O.H. TOLLEY, JR. AND BETTY TOLLEY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11407-95. Filed May 29, 1997. William H. Scheil, Jr. , for petitioners. Ve…
  5. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003related by meaning
    rders) applies for transfers, distributions, and payments made after December 31, 2001. Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
  6. 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…
  7. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  8. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  9. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …K-1 issued to petitioner indicates that petitioner's share of partnership liabilities at the end of 1990 was $69,756. Luther Thompson, a partner at Heidelberg & Woodliff, testified that he could not vouch for the accuracy of that figure because it was handwritten and not typewritten like the remainder of the schedule. …
  10. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016related by meaning
    …2d 90 (8th Cir. 1971); see also White v. Commissioner, 991 F.2d 657, 661-662 (10th Cir. 1993), T.C. Memo. 1991-552. The test is whether a reasonable person would discern from the return that the disputed gross income is omitted. See Univ. Country Club, Inc. v. Commissioner, 64 T.C. 460, 471 (1975). The parties agree th…
  11. T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen…
    IRCTreasury DecisionsFeb 26, 2007related by meaning
    addition, the notice invites comments from the public regarding all aspects of these provisions. ADMINISTRATIVE Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
  12. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …/employer relationship. See, e.g., Eren v. Commissioner , supra ; Marckwardt v. Commissioner , T.C. Memo. 1991-347; Juliard v. Commissioner , T.C. Memo. 1991-230; Matt v. Commissioner , T.C. Memo. 1990-209. - 31 - Other cases have found that the taxpayer was an independent contractor. See, e.g., Chin v. United States ,…
  13. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    o any participant which exceed the limitations of section 415(b). Paragraph (1) of subsection (d) shall not apply for purposes of this subparagraph.”. (c) Effective Date. — The amendments made by this section shall apply to taxable years beginning after December 31, 1978. [Senate Amendment to H.R. 4961, July 23 (legisl…
  14. Treas. Reg. § 54.4979-1(c)(4) — Excise tax on certain excess contributions and excess aggregate contributions.
    IRCRegulationsJul 26, 2017
    …he excess contributions or making qualified nonelective contributions (QNECs). (ii) On December 31, 1990, X determines that Y does not satisfy the actual deferral percentage test for the 1990 plan year, and that excess contributions for the year equal $5,000. On March 1, 1991, Y distributes $2,000 of these excess contr…
  15. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    ive taxable years from 1988 through 1990. Ms. Johnson received $20,580, $31,200, and $15,600 during the same respective years. Neither of the Johnsons received any compensation from Roofing during their 1991 through 1993 taxable years. The Johnsons filed timely their joint 1990 Federal income tax return. On March 3, 19…
  16. DOL EBSA (final agency order) — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. NORTHWESTERN INSTITUTE OF PSYCHIATRY
    ERISACourt RulingsJul 26, 1995
    … will be forwarded to you when completed." The IRS sent NIP a second deficiency letter on March 20, 1990, noting that Schedule. B and the IQPA's opinion was still missing, and that some information was missing from the Schedule C that was provided, and reiterated the penalties which could be levied by the IRS and the D…
  17. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021
    was entered into before January 1, 1989, and— (A) The increase occurs before April 1, 1990, or (B) The amount of the increase does not exceed $50,000. (3) Illustration. (i) If federal executive agency enters into an initial contract on December 1, 1988, and the amount of money obligated under the contract is increased …
  18. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    a reasonable .dispute with respect to any item of income reported on an information return filed with the Secretary by a third party :and the taxpayer has "fully cooperated with the Secretary (including providing,,-, within ,a reasonable period-of time, access to and inspection of, all witnesses, information, and docum…
  19. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  20. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    … filed, and thus become a part of the record. They are accordingly referred to in this Supplemental Memorandum Opinion to the extent we deem it necessary to do so to address arguments contained in petitioner's Motion and Judicial Notice Motions. - 4 - Rule 201(f) of the Federal Rules of Evidence provides that judicial …