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83 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    … 1,943,815 1,979,855 Inc. 2 Greenstone 305,000 250,000 377,051 367,000 Roberts Adv. 3 Interpublic 1,652,525 1,705,044 1,635,232 1,437,983 Group of Cos. 4 Laser N/A N/A N/A 109,826 Vision Centers, Inc. Omnicom Group 780,000 957,500 1,053,750 1,168,750 75th %tile 965,600 964,800 1,106,100 955,700 5 Regression Est. 1 Empl…
  2. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012related by meaning
    ditional tax provided by section 72(t)), penalties, and statutory interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record . 12 - does not establish that petitioners received a.notice of deficiency for 2007 and consequently a challenge to petitioners' 2007 tax liability is allowed in thi judicial p…
  3. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
  4. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
  5. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    999 taxable year. Respondent contends that, with respect to the $12,880.04 distribution from petitioner’s TSP, petitioners are subject to a 10-percent additional tax on an early distribution from a qualified retirement plan under section 72(t)(1). Petitioners contend that they are not subject to the 10percent additiona…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ip return for 1987, MIT 86 reported partnership taxable income of $4,855,505, which consisted of $4,652,314 (the deferred income that it reported due to the change in accounting method), plus $203,191, which it called fee income and which represented the accrual of interest payable from MPC, and no expenses. For the ye…
  7. T.C. Memo. 2007-348 — Charles R. Cutler v. Commissioner
    IRCCourt RulingsNov 26, 2007
    …that there is no genuine issue as to any material fact. Morrison v. Commissioner , 81 T.C. 644, 651-652 (1983). Based upon our review of the record, we are satisfied that there is no genuine issue of material fact and that respondent is entitled to judgment as a matter of law. The deficiencies in this case arise from p…
  8. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    …lified person of the income or assets of a plan”. 3 See O’Malley v. Commissioner , 96 T.C. 644, 651-652 (1991), affd. 972 F.2d 150 (7th Cir. 1992). Under section 4975(c)(1)(E), each of the three loans also was a direct or indirect “act by a disqualified person who is a fiduciary whereby he deals with the income or asse…
  9. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    …The parties stipulated that the Trust’s account limit for 1991, as defined in sec. 419A(c), was $65,652,991. However, that stipulation is contrary to the record in this case. The record establishes, and we have found, that that account limit was $64,615,936. We may, and we shall in this instance, disregard a stipulatio…
  10. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
  11. 54 T.C. 1057 — Bernard McMenamy, Contractor, Inc. v. Commissioner
    IRCCourt RulingsMay 25, 1970
    …26, restated in Rev. Rul. 68-654, 1968-2 C.B. 179; and P.S. No. 28 (1944), restated in Rev. Rul. 68-652, 1968-2 C.B. 176. In these rulings, he made clear that in his opinion, prohibited discrimination occurs when, as a result of using the years of service, the ratio between the employer contributions allocated to the a…
  12. 81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    of the Code and a health savings account described in section 223(d) of the Code. Back to Citation 19.  Code section 4975(c)(2). Back to Citation 20.  Angela A. Hung, Noreen Clancy, Jeff Dominitz, Eric Talley, Claude Berrebi, Farrukh Suvankulov, Investor and Industry Perspectives on Investment Advisers and Broker-Deal…
  13. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  14. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    now how these deductions were calculated. She did not substantiate such expenses. Therefore, this Court holds that such deductions are not allowed and respondent’s disallowance of such deductions is sustained. Due to our holding that petitioner has not substantiated any of the claimed Schedule C deductions for Port of …
  15. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …fits Total Percent Normal cost $351,815 $1,057,021 $1,408,836 O Accrued liability: Active employees 652,308 1,710,610 2,362,918 CD Retirees 8,892,721 22,637,914 31,530,635 CO 05 00 9,896,844 25,405,545 35,302,389 Petitioner contributed $35,300,000 to the VEBA trust on December 29, 1986. Petitioner claimed a deduction f…
  16. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    is to be -6included in gross income in the year in which the payment is received rather than in the years to which the payment is attributable, to the extent that application of the formula results in a taxable amount. The election merely provides an alternative method of applying the formula to determine the taxable p…
  17. 39 T.C. 1055 — Cohen v. Commissioner
    IRCCourt RulingsMar 27, 1963
    …years indicated For each $1,000 of face amount; cash or loan value 1_ __ $623.23 2_ __ 637.58 3_ __ 652.35 4_ __ 667.57 5_ __ 683.23 6_ __ 699.36 7_ __ 715.96 8_ __ 733.08 9_ __ 750.74 10_ __ 768.97 11_ __ 787.82 12_ __ 807.35 13_ __ 827.61 14_ __ 848.70 15_ __ 870.71 16_ __ 893.76 17_ __ 918.01 18_ __ 943.64 19_ __ 97…
  18. Rev. Rul. 2013-2 — 2013 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2013 are provided for use in …
    IRCRevenue RulingsMar 4, 2013related by meaning
    INCOME TAX Notice 2013-12 Notice 2013-12 This notice reports the results of the section 48C Phase I program and, as provided by section 48C(d)(4) of the Code, establishes a second phase of the qualifying advanced energy project program (“the section 48C Phase II program”) to distribute the section 48C Phase I credits t…
  19. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    … 809. 13 Subtotal_ 314, 395. 38 Administration expense at 3.3%_ 25, 743. 31 50% of net income_ 288, 652. 07 15% of adjusted gross income from feldspar_ 50, 377. 70 5% of adjusted gross income from sand_ 1, 067. 66 Total percentage depletion_ 71, 445. 36 Allowable depreciation_ 71, 445. 36 Pacific Geove, California, Pro…
  20. 89 FR 58886 — Required Minimum Distributions
    IRCFinal Rules (FR)Jul 19, 2024
    … 26,482 519,151 2031 864,291 529,534 524,342 26,760 502,774 2032 819,740 512,829 507,801 27,177 485,652 2033 775,430 495,365 490,509 27,438 467,927 2034 731,620 477,286 472,606 27,853 449,433 1  $1,000,000 death benefit reduced 4.55 percent for withdrawal during 2028. ( printed page 58928) 2  Notional account balance a…