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86 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    Memo. 2002-18, 83 T.C.M. (CCH) 1107 , 1108– 10 (imposing penalty of $2,000 under section 6673(a)), af f’ d , 54 F. App ’ x 254 (9th Cir. 2002) ; s ee G reat - West Life Assurance Co. v. United States , 678 F.2d 180, 183 ( Ct. Cl. 1982) (“The determination of where income is derived or ‘sourced’ is generally of no mome…
  2. T.C. Memo. 2001-9 — WSB Liquidating Corporation v. Commissioner
    IRCCourt RulingsJan 19, 2001
    …uracy-related penalties, as follows: Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1993 $11,805 $1,915 1994 13,511 1,554 1995 14,307 1,597 - 2 - Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of…
  3. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    f $2,000 under section 6673(a)), af[d, 54 F. App'x 254 (9th Cir. 2002). And his argument that he had no obligation to file a Federal income tax return because he was not a trustee or the executor of an estate--an argument evidently based on the fact that IRS Form 1040 and Code section 1040 happen to share the same four…
  4. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    4. Respondent has allowed exactly those amounts as deductions for 2004 and 2005. Petitioner has made no attempts to provide the Court with evidence of any other payments for travel and meals and entertainment expenses. With the heightened substantiation requirements under section 274 and the lack of additional document…
  5. T.C. Summary Opinion 2007-187 — Wayne Smith v. Commissioner
    IRCCourt RulingsNov 1, 2007
    …RA accounts : Year Amount Held in IRA Amount Issued to Petitione r (Form 5498) (Form 1099-R ) 1998 $805,349 $428,89 9 1999 538,390 83,37 3 2000 383,631 61,17 8 2001 222, 290 80, 07 7 2002 159,406 38,60 6 2003 145,155 23,17 7 With respect to the establishment and value of petitioner's bifurcated accounts, and the amount…
  6. 119 T.C. No. 6 — Robert Ancira v. Commissioner
    IRCCourt RulingsSep 24, 2002related by meaning
    titioner is not liable for the sec. 6662 penalty. 3 S.K. apparently stands for Smoothie King, which we gather was the trade name of a product. OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 The Court agrees with and…
  7. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
  8. 75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans
    ERISAProposed Rules (FR)Proposed Aug 30, 2010related by meaning
    s assessed by the Treasury and Labor Departments in connection with prior prohibited transactions —The current version of § 2570.35(a)(14)(v) requires ( printed page 53177) an applicant to disclose whether any excise taxes due under sections 4975(a) and (b) of the Code by reason of a consummated exemption transaction h…
  9. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    an incident date. To determine whether Congress has spoken to this question, we consider the “plain” and “literal” language of the statute itself, the specific context in which the language is used, and the broader context of the statute as a whole. See Robinson v. Shell Oil Co. , 519 U.S. 337, 341 (1997); Allen v. Uni…
  10. T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred…
    IRCTreasury DecisionsFeb 6, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-7 Rev. Rul. 2006-7 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 February 2006. T.D. 9238 T.D. 9238 Temporary and proposed regul…
  11. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012
    …rted owning a single family home valued at $650,000 (subject to one or more mortgages totaling $889,805), zero equity, and a monthly mortgage payment of $5,862. According to the Form 433-A, petitioners' home was the subject of a foreclosure proceeding. Petitioners further reported on the Form 433-A disposable income of…
  12. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026related by meaning
    l issue relevant to ascertaining the taxpayer’s liability for any tax imposed by subtitle A or B and meets other prerequisites, the Commissioner shall have the burden of proof with respect to that issue. See Higbee v. Commissioner, 116 T.C. 438, 440– 41 (2001). We need not decide whether the burden shift s to responden…
  13. T.C. Memo. 2003-294 — Randolph S. Simpson, I v. Commissioner
    IRCCourt RulingsOct 21, 2003
    …tribution from U.S. Trust Co. of California in October 1997. The amount of the distribution was $42,805.55, out of which 20 percent Federal income tax was withheld. Petitioner received a check in the net amount of $34,244.44 and was thereafter issued Form 1099-R, Distributions From Pensions, Annuities, Retirement or Pr…
  14. Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum…
    IRCRevenue RulingsNov 26, 2007related by meaning
    INCOME TAX T.D. 9362 T.D. 9362 Temporary and proposed regulations under section 905 of the Code provide rules relating to a United States taxpayer's obligation to notify the Internal Revenue Service of a foreign tax redetermination, which is a change in foreign tax liability that may affect the taxpayer's foreign tax c…
  15. 85 T.C. 869; 85 T.C. No. 51 — Griswold v. Commissioner
    IRCCourt RulingsNov 26, 1985related by meaning
    rance company.) [H. Rept. 93-807, supra at 136-137, 1974-3 C.B. (Supp.) at 236, 371-372. See also Conf. Rept. 93-1280, at 339, 1974-3 C.B. 415, 500.[] The foregoing excerpt from the legislative history of section 408(c)(3) makes it clear that petitioner’s borrowing from John Hancock against his annuity contract was pre…
  16. T.C. Summary Opinion 2005-108 — Magellean Askew, Jr. v. Commissioner
    IRCCourt RulingsAug 1, 2005related by meaning
    his annuity policies. As stated earlier, section 72(e)(5) applies to the surrender of an annuity contract. See sec. 72(e)(5)(E). Absent exceptions not applicable in the instant case, the law is well settled that a distribution upon the complete surrender of an annuity contract is includable in gross income to the exten…
  17. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ternal Revenue Code of 1939 was not definitively resolved. 99 Internal Revenue Code of 1939. Sec . 7805(b) of the Internal Revenue Code of 1986 was substantially the same as sec . 7 805(b) of the Internal Revenue Code of 1954 until it was amended in 1996. With the 1996 amendment, a Treasury regulation can be made retro…
  18. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    … that introduced FSCs to the Code. See Deficit Reduction Act of 1984, Pub. L. No. 98-369, secs. 801-805, 98 Stat. at 985-1003; Revenue Act of 1971, Pub. L. No. 92-178, secs. 501-507, 85 Stat. at 535-553. FSCs were created to replace the pre-1984 version of DISCs. See generally Boris I. Bittker & James S. (continued...)…
  19. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  20. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …osition. Coca- Cola , 155 T.C. at 202 (citing Lufkin Foundry & Mach. Co. v. Commissioner , 468 F.2d 805, 807 – 08 (5th Cir. 1972), rev’g and remanding on other grounds T.C. Memo. 1971-101). For some transactions —namely, those involving high-profit intangibles —comparable transactions between unrelated parties simply d…