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’ …
IRCCourt RulingsOct 29, 2013related by meaning
s amount includes the additional tax of $32,137 under sec. 72(t).
- 27 -
[*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec.
1.6664-4(b)(1), Income Tax Regs.
The parties have agreed in the stipulation of settl…
83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCProposed Rules (FR)Proposed Oct 29, 2018
9,024
1,162,461
20,737
3 year Average
2,005
255,459
6,016
774,974
11,751
Table 3—Proposed Recordkeeping and Reporting Requirements
Regulation section OMB
Control No.
Respondents
Responses
Burden per
response
(hours)
Total annual
burden
(hours)
Hourly labor
cost of
reporting
Total labor
cost of
reporting
Printing and
m…
Rev. Rul. 2006-43 — Government pick-up plans; employer contributions; income tax; prospective application. This ruling describes the actions required for a state or its political … IRCRevenue RulingsAug 28, 2006
…of employees until such time as they are distributed to the employees. Rev. Rul. 81-35, 1981-1 C.B. 255, and Rev. Rul. 81-36, 1981-1 C.B. 255, address certain requirements for contributions to be picked up by an employer within the meaning of § 414(h)(2). These revenue rulings establish that the following criteria must…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
REG-152914-04 — Proposed regulations under section 417 of the Code would revise final regulations (T.D. 9099, 2004-2 I.R.B. 255) under section 417(a)(3) concerning content req… IRCProposed Rules (FR)Proposed Feb 28, 2005
…ublished in the Federal Register on December 17, 2003. See §1.417(a)(3)-1 (T.D. 9099, 2004-2 I.R.B. 255 [68 FR 70141]). The 2003 regulations are generally effective for QJSA explanations provided with respect to annuity starting dates beginning on or after October 1, 2004.
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCRegulationsDec 30, 2016
…mergency service received by the individual, the reasonable amount calculated using this method is $116. The amount that would be paid under Medicare for the emergency service, excluding any copayment or coinsurance for the service, is $80. (ii) Conclusion. In this Example 5, the plan is responsible for paying $92.80, …
IRCCourt RulingsAug 19, 2009related by meaning
statutory provisions by numerous
cases . On the record before us, we are satisfied that
petitioners acted in good faith and with reasonable cause with respect to that portion of the underpayment relating to the 10percent additional tax under section 72(t) . Such was not the
case with respect to the understatement relat…
Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 2026
…t applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (FCAA), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), section 104 of Division M of the FCAA, known as the Bipartisan American Miners Act of 2019 (Mine…
IRCCourt RulingsNov 14, 1996related by meaning
ear that were
listed in the letter of credit, in the amount of $2,092,421. By
way of a net operating loss carryback, petitioner also claimed a
- 5 -
3 [T]he words of such an act as the Income Tax * * *
merely dance before my eyes in a meaningless
procession: cross-reference to cross-reference,
exception upon exception …
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…t applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (FCAA), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), section 104 of Division M of the FCAA, known as the Bipartisan American Miners Act of 2019 (Mine…
T.C. Memo. 2017-77 — Estate of Hung-Liang Lynn Lin, Deceased, Jeffrey S. Lin, Administrator v. Commissioner IRCCourt RulingsMay 8, 2017
…taxpayer acted in good faith with respect to such portion.
Sec. 6664(c)(1); Higbee v. Commissioner, 116 T.C. at 446-447. The
determination of whether the taxpayer had reasonable cause and acted in good
faith depends upon the pertinent facts and circumstances of a particular case. Sec.
1.6664-4(b)(1), Income Tax Regs. W…
IRCCourt RulingsDec 2, 2010related by meaning
bility for income tax for
2004 that exceeded $1,000, net of any section 31 credit, and has
taken judicial notice of the fact that petitioner had a tax liability in 2003. Therefore, the Court sustains respondent's
determination of the addition to tax pursuant to section 6654(a).
The Court has considered all of petitione…
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018
…le, they had reasonable cause and acted in good faith. See sec. 6664(c)(1); Higbee v.
Commissioner, 116 T.C. at 446-447.
The determination whether the taxpayer had reasonable cause and acted in
good faith depends upon the pertinent facts and circumstances of a particular case.
Sec. 1.6664-4(b)(1), Income Tax Regs. We c…
IRCCourt RulingsApr 20, 2017related by meaning
ish the tax shown on the taxpayer's return for the preceding year or
demonstrate that the taxpayer filed no such return. See Wheeler, 127 T.C. at 212; Schlussel v. Commissioner, T.C. Memo. 2013-185.
Respondent met his burden of production by including with his summary
judgment motion a redacted Form 4340 showing that p…
IRCCourt RulingsJan 28, 2014
…spect to
any penalty, including the accuracy-related penalty. Sec. 7491(c); Hiebee v.
Commissioner, 116 T.C. 438, 446 (2001). To meet that burden, the Commissioner
must come forward with sufficient evidence indicating that it is appropriate to
impose the relevant penalty. Hiebee v. Commissioner, 116 T.C. at 446. Howeve…
IRCCourt RulingsDec 2, 2013related by meaning
T.C. Summary Opinion 2013-96
UNITED STATES TAX COURT
SAMUEL BRACH AND LILLIAN BRACH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15460-12S. Filed December 2, 2013.
Ronald Jay Cohen, for petitioners.
Gennady Zilberman, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was h…
IRCCourt RulingsOct 25, 2006
return, petitioner properly
reported the $116,251 .20 distribution as income but did not
report the 10-percent additional tax for early distributions under section 72(t) . In the notice of deficiency, respondent
determined that petitioner was liable for the 10-percent
additional tax on the early $116,251 .20 distribut…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…