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76 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    have considered all of the contentions and arguments of petitioner that are not addressed herein and find them to be without merit and/or irrelevant. active participation by petitioner. Petitioner initiated, received, and controlled the withdrawals from his IRA's, which he used to pay Ms. Czepiel the sum of $30,300 whi…
  2. 54 T.C. 1679 — Clarke v. Commissioner
    IRCCourt RulingsAug 31, 1970related by meaning
    ement Date applicable to any such Participant, subject only to the payment to any sudh Participant of the full amount of his equity in the Trust Fund. Under the terms of the trust, those participants who declined to withdraw their vested interests pursuant to section XIII-A, or their beneficiaries, may receive distribu…
  3. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    …r we have jurisdiction. Hambrick v. Commissioner, 118 T.C. 348 (2002); Pyo v. Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83 T.C. 309, 314 (1984). Our Rules are silent as to deciding a motion to dismiss for lack of subject matter jurisdiction. Thus, we look to the Federal Rules of Civil Procedure. Se…
  4. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. - 9 - 5 See also …
  5. T.C. Memo. 2007-348 — Charles R. Cutler v. Commissioner
    IRCCourt RulingsNov 26, 2007
    …l estate tax attributable to the IRD. Sec. 691(c); Estate of Smith v. United States , 391 F.3d 621, 626 (5th Cir. 2004); Estate of Kahn v. Commissioner , 125 T.C. 227, 232 (2005). to the beneficiary, the portion equal to the value of the IRA on the date of the decedent’s death, less any nondeductible contributions made…
  6. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    tax for the same taxable year * * * except in the case of fraud” if respondent has - 5 - mailed a notice of deficiency under section 6212(a) “and the taxpayer files a petition with the Tax Court within the time prescribed”. Hemmings v. Commissioner , 104 T.C. 221, 226-228 (1995). In this case, petitioners did not file…
  7. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978related by meaning
    41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
  8. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …5 1986 1987 Assets: Cash $100 $19,908 $18,932 $51,292 ($26,366) Investments 420,000 -0--0-923,755 1,626,112 Receivables due from employer 1,725,684 2,388,824 2,372,554 516,399 -0- Total assets 2,145,784 2,408,732 2,391,486 1,491,446 1,599,746 Liabilities: Unpaid claims 379,002 377,225 327,989 857,071 853,771 Net Assets…
  9. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018related by meaning
    t was not a payment. The levy proceeds were an involuntary payment, and therefore R did not abuse his discretion in applying the levy proceeds against Ps' 1995 income tax liability. Hel_d, further, R's determination to deny Ps' installment agreement proposal was not an abuse of discretion. Juan F. Vasquez, Jr., and Ren…
  10. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    …contributions $42,000,000.00 -01 $40,737,374.59 2 $50,783,404.03 Employee contributions -0- $ 1,555,626.86 1,841,554.51 2,505,955.35 Interest earned 3 773.98 1,749,030.80 78,641.10 -0Benefits paid -0- 39,153,640.83 48,808,587.03 53,289,359.38 Ending balance 42,000,773.98 6,151,016.83 -0- -01 Represents the total of pet…
  11. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016related by meaning
    or an increased deficiency, which means that we will not enter in our decision a deficiency greater than that shown in the deficiency notice. See sec. 6214(a); Estate of Petschek v. Commissioner, 81 T.C. 260, 271-272 (1983), afCd, 738 F.2d 67 (2d Cir. 1984); see also Koufman v. Commissioner, 69 T.C. 473, 475476 (1977).…
  12. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  13. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    … we have jurisdiction. Hambrick v. Commissioner, 118 T.C. 348 (2002); Pyo v.. Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83 T.C. 309, 314 (1984). 9Codified, in part, at sec. 7623(b). '°We decided this issue in Whistleblower 11332-13W v. Commissioner, 142 T.C. _ (June 4, 2014), also filed today. - 7 …
  14. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    ent has failed to establish the amount of funds that Mr. Cujas may have received during 1993 for such services. Therefore, respondent has failed - 9 - to meet his burden of proof. Accordingly, we hold that petitioners are not liable for the deficiencies relating to 1993. II. Respondent's Other Determinations Respondent…
  15. T.C. Summary Opinion 2012-74 — Charles Grant & Elizabeth A. Beech v. Commissioner
    IRCCourt RulingsJul 26, 2012
    …. The judiciary is not authorized to redraw the boundaries." Kim v. Commissioner, 579 F.3d 623, 625-626 (7th Cir. 2012), afg T.C. Dkt. No. 11902-10 (May 20, 2011) (bench opinion).
  16. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross income rental income of $4,920 they received in 2007. - 3 - [*3] to deduct a net operating loss (…