IRCCourt RulingsFeb 25, 2016
on of the deficiencies,
penalties, and additions to tax for 2004 and 2005.
In his answering brief respondent concedes that petitioner is entitled to a deduction for an additional $15,800 in travel expenses previously disallowed for
2004. Respondent also concedes that petitioner is not liable for an enhanced
accuracy-re…
IRCCourt RulingsJan 14, 2013
lated penalty with respect to
all of its concessions listed in this paragraph.
[*4] for the 2003, 2004, and 2005 tax years, including the pension plan contributions paid on behalf of Robert A. and Pearl Fletcher for the 2003 and 2004
tax years,
(2) whether the compensation TORCH paid to the Fletchers' daughter,
Grace-A…
IRCCourt RulingsDec 18, 2012
…clude dismissal of this case and entry of * * * decision[s] against petitioner[s]."
On December 20, 2004, respondent filed motions to impose sanctions on the
grounds that petitioners had failed to comply with the Court's November 10, 2004,
- 28 -
[*28] orders, in that petitioners had not made available to respondent's …
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…
IRCCourt RulingsOct 31, 2007
…ve on
during 2005 .
Petitioner requested a distribution from his retirement account in mid-November 2004 . The distribution did not take as
long to process as anticipated . Petitioner received $ 62,467 .58
from his retirement account in December 2004 . PSRS withheld
$12,493 .52 in Federal tax from the distribution . Pe…
IRCCourt RulingsJun 14, 2012
…her WFR and Yolo would issue
dividends to their shareholders.
II. Yolo's Medical Plan
On January 2, 2004, Mrs. Repetto in her capacity as president of Yolo
established a medical and dental care expense reimbursement plan (Yolo medical
plan) effective January 1, 2004. According to the Yolo medical plan,. Yolo would
reim…
IRCRegulationsSep 9, 2016
… using the fair market value of stock as of the date on the option is granted. During calendar year 2004, the aggregate fair market value of stock with respect to which E's options are exercisable for the first time exceeds $100,000. Therefore, the option for Y Corporation stock is treated as an incentive stock option,…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
IRCCourt RulingsFeb 10, 2009related by meaning
ic v . ,Commissioner , T .C . Memo . 1992--
609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . .
In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her
medical condition
. She explained at trial that although she
received treatment from doctors in 2005, she did …
T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a … IRCTreasury DecisionsMay 7, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-29 Rev. Rul. 2007-29
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007.
Announcement 2007-44 Announcement 2007-44
This anno…
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
IRCCourt RulingsSep 13, 2010
Memo . 1997-331 ; Speer v .
Commissioner
Memo . 1993- 5
The fol
accuracy of
appears exce
amount of ti
(2) the Geor
during 2004 .
Further
petitioner c T .C . Memo . 1996-323 ; Goshorn v . Commissioner , T .C .
1 8 .
owing factors further diminish the credibility and
etitioner's claim : (1) The number of hours claimed
~…
IRCCourt RulingsApr 2, 2020
… "supposed to make any other assessments [of tax]
for that year." The examination of the Goldbergs' 2004 tax year could yield deficiencies and additions to tax, which would in turn lead to assessments of tax.
If the IRS accepted Goldberg's pending offer-in-compromise while the 2004
examination was still taking place, t…
IRCCourt RulingsOct 24, 2007
…eturn. See, e.g., Hopkins v.
Commissioner
, 121 T.C. 73, 88-89 (2003); Knorr v. Commissioner
,
T.C. Memo. 2004-212; Morello v. Commissioner
, T.C. Memo.
2004-181; Keitz v. Commissioner
, T.C. Memo. 2004-74; Ogonoski v.
- 35 -
Commissioner
, T.C. Memo. 2004-52; Wiest v. Commissioner
, T.C.
Memo. 2003-91; see also Rev. P…
IRCCourt RulingsMay 11, 2009
…ry 1 5
each year for a period based on petitioner wife's life
expectancy . On or-before January 15, 2004, petitioner wife
received a $102,311
.50 distribution from her IRA in accordance
with-her election to receive a series of-substantially equal
periodic payments
. During 2004 petitioner wife received two
additional d…
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
…nternal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
REG-111833-99 REG-111833-99 Proposed regulations under section 7430 of the Code relate to awards of administrative costs and attorneys fees to conform the regulations to the amendments made in the Taxpayer Relief A…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
Rev. Proc. 2005-25 — Fair market value; distributions; qualified retirement plans. This procedure provides guidance, including examples, of how fair market value may be determined … IRCRevenue ProceduresApr 25, 2005
…evenue procedure applies to distributions, sales, and other transfers made on or after February 13, 2004, to permanent benefits within the meaning of § 1.79-0 provided on or after February 13, 2004, and to non-exempt employees’ trusts under § 402(b) for periods on or after February 13, 2004. However, for periods before…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…