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83 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  2. T.C. Summary Opinion 2008-160 — Renita Rose Best v. Commissioner
    IRCCourt RulingsDec 23, 2008related by meaning
    v . Commissioner , 111 T .C . 250, 255 (1998) ; Milner v . Commissioner , T .C . Memo . 2004-111 ; Gallagher v . Commissioner , T .C . Memo . 200134 . We conclude that petitioner is liable for the $1,971 10percent additional tax on her early $19,706 IRA distribution . Decision will be entere d for respondent .
  3. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
    IRCRegulationsJul 12, 2016
    …bying Nontaxable amount (LNTA) Lobbying expenditures (LE) 1979 $400,000 (20% of $400,000=) $80,000 $100,000 1980 300,000 (20% of $300,000=) 60,000 100,000 1981 600,000 (20% of $500,000 + 15% of $100,000=) 115,000 120,000 1982 500,000 (20% of $500,000=) 100,000 100,000 Totals 1,800,000 355,000 420,000 (2) Organization X…
  4. 29 C.F.R. § 4022.61(f) — Limitations on benefit payments by plan administrator.
    PBGCRegulationsJan 1, 2017
    …nder paragraph (b) of this section, the plan administrator must reduce the temporary supplement to $100 per month.For the purpose of determining whether the reduced benefit, i.e., a level-life annuity of $1,100 per month and a temporary annuity supplement of $100 per month to age 62, exceeds the maximum guaranteeable b…
  5. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
  6. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  7. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …31.9 percent for - 52 - 23 The combined tax rate for 1991-92 is computed as follows: Starting point 100.0% Minn. State tax at 9.8% (100 x 9.8%) - 9.8 90.2 Federal tax at 29% (90.2 x 29%) -26.2 64.0 Combined tax rate (100% - 64%) 36 24 The combined tax rate for 1993-94 is computed as follows: Starting point 100.0 % Minn…
  8. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …
  9. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …500 James McGivern Reg. Sales Mgr. 25,000 299,500 324,500 David Terry Sales V.P.-Central 55,000 217,100 272,100 William Shaw V.P. Sales & 85,000 172,100 257,100 Marketing Jim Morrissey Sales Manager 55,000 200,300 255,300 (Chicago) - 15 - FY-91 James McGivern Reg. Sales Manager 40,000 122,100 262,100 Wayne Heus Sales M…
  10. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005
    …33(a)(1) return.¹ For the reasons discussed below, we shall grant responde;nt's motions. Background 100 Oak Street Corporation (100 Oak Street) is a wholly owned subsidiary of Service Employees International Union (Service Employees) (collectively referred to as petitioners). Petitioners share the same address, and man…
  11. T.C. Summary Opinion 2003-153 — Joseph Jones v. Commissioner
    IRCCourt RulingsOct 20, 2003related by meaning
    result apparently so at odds with accepted tax policy.” Darby v. Commissioner , supra at 68. We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner properly included the full distribution in his 1999 gross income. Accordingly, we hold that petitioner is l…
  12. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  13. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    services is $100,000. Assume that the district director proposes to increase D’s income by $100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior to the first occurring of the events described in subdivisions (i), (ii), or (iii) of this subparagraph, D ele…
  14. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    he Federal Government generally constitute gross income unless excluded by law. Schuller v. Commissioner, T.C. Memo. 2012-347; sec. 1.61-11(a), Income Tax Regs. For a taxpayer who uses the cash receipts and disbursements method of 7 Petitioner's assertion was tried by the consent of the parties. See Rule 41(b). - 7 - a…
  15. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  16. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021
    22, and from 100 to 10, for returns required to be filed during calendar years after 2022. See section 2.C., Amending the electronic-filing threshold. G. Special Electronic-Filing Rule for Partnerships Having More Than 100 Partners Paragraph (6) of section 6011(e), as that section was amended by the TFA, provides, “Not…
  17. Treas. Reg. § 54.9816-1T(a) — Basis and scope (temporary).
    IRCRegulationsOct 7, 2021related by meaning
    …816-2T through 54.9816-8T, 54.9817-1T, 54.9817-2T, and 54.9822-1T implement subchapter B of chapter 100 of the Internal Revenue Code of 1986.
  18. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005related by meaning
    . 213 shall be deemed paid for by a portion of petitioner’s withdrawal from his thrift savings plan and are therefore excepted from the additional tax under sec. 72(t). Respondent further concedes that petitioner’s filing status is married filing jointly. Respondent determined a deficiency in petitioner’s Federal incom…
  19. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    …977); United States v. Haldeman, 559 F.2d 31, 136 (D.C. Cir. 1976); United States v. Mine, 466 F.2d 1000, 1003-1004 (7th Cir. 1972). Because we have declined petitioners' attempts to have this case treated as a small tax case, petitioners have the right to challenge those rulings on appeal. IRA Distributions Taxation o…
  20. 79 FR 61440 — Liquidity Coverage Ratio: Liquidity Risk Measurement Standards
    IRCFinal Rules (FR)Oct 10, 2014
    …orth in this final rule (the HQLA amount, which is the numerator of the ratio) that is no less than 100 percent of its total net cash outflows over a prospective 30 calendar-day period (the denominator of the ratio). The agencies recognize that, under certain circumstances, it may be necessary for a covered company's L…