IRCCourt RulingsFeb 28, 2024related by meaning
stituting a 6-year period in lieu of the 3-year
period otherwise referred to in such subsection.
(D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market
value, subparagraph (A) shall not apply.
Section 313(…
Ann. 2004-52 — Correction; section 457; Rev. Rul. 2004-57. A transition rule is set forth for a plan established before June 14, 2004, that does not satisfy the requirements … IRCAnnouncementsJun 14, 2004
Announcement 2004-52
Correction Under Rev. Rul. 2004-57
Rev. Rul. 2004-57, page this Bulletin, provides that an eligible governmental plan under § 457(b) of the Internal Revenue Code must be established and maintained by an eligible employer as defined under § 457(e)(1)(A). A plan established before June 14, 2004, that…
IRCCourt RulingsApr 25, 2011related by meaning
…ucing activity. See, e.g., Pittman v. Commissioner,
100 F.3d 1308, 1313 (7th Cir. 1996), affg. T.C. Memo. 1995-243;
Notice 2004-78 — Actuarial assumptions; distributions under section 101 of Pension Funding Equity Act of 2004. This notice provides guidance in question and answer format on th… IRCNoticesNov 29, 2004
he plan year beginning in 2004 to an equivalent straight life annuity using 5.5% rather than the applicable interest rate of 5.25% as under prior law. In such a case, to satisfy the limitations of § 415 of the Code, the maximum single-sum distribution for a participant who is age 65 in 2004 would be $1,866,645 calculat…
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 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 RulingsAug 28, 2008related by meaning
T .C . Memo . 2008-20 4
UNITED STATES TAX-COUR T
WALTER KOWSH, Petitioner v .
COMMISSIONER OF . INTERNAL . REVENUE, Responden t
Docket No . 15154-06 . Filed August 28, 2008 .
Walter Kowsh, pro se .
Michelle L . Maniscalco , for respondent .
MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N
KROUPA, Judge : Respondent determined…
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 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 RulingsNov 1, 2005related by meaning
…d all Rule references
are to the Tax Court Rules of Practice and Procedure. All
(continued...)
T.C. Memo. 2005-258
UNITED STATES TAX COURT
JOYCE M. THOMAS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10824-03. Filed November 1, 2005.
Joyce M. Thomas, pro se.
Andrew R. Moore
, for respondent.
…
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
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,…
IRCCourt RulingsAug 31, 2021related by meaning
including granting CNC status - - s ince petitioner did not furnish necessary
documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of
collection with the concerns of petitioner. On the basis of our review w e hold that
M s. Rego…
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,…
IRCCourt RulingsAug 25, 1997related by meaning
motion for costs
was filed out of time and should be "dismissed" for that reason.
We reject respondent's contention and do not consider it further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after …
Rev. Proc. 2004-15 — Minimum funding standards; waivers; notice. This procedure sets forth guidelines for requesting waivers of the minimum funding standards with respect to define… IRCRevenue ProceduresFeb 17, 2004
…nces, preliminary conferences may be afforded in addition to conferences available under Rev. Proc. 2004-4, 2004-1 I.R.B. 125.
SECTION 6. BANKRUPTCY PETITIONS
If the applicant or a significant number of controlled group members file a bankruptcy petition after the request for a waiver of the minimum funding standard is…
IRCCourt RulingsMay 8, 2006related by meaning
002, it could not have been determined
whether petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defini…
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.…
IRCCourt RulingsSep 25, 2019related by meaning
… T.C. 518, 520
- 11 -
[*11] (1992), affd, 17 F.3d 965 (7th Cir. 1994); Murphy v. Commissioner, T.C.
Memo. 2019-72, at *7.
The regulations provide that a taxpayer has reasonable cause for failure to
timely pay a tax if "the taxpayer has made a satisfactory showing that he exercised
ordinary business care and prudence in…