IRCCourt RulingsOct 3, 1995related by meaning
ch 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.
- 18 -
16 We also observe that the Transfer Refund was paid to
petitioner "on account of" his election to transfer from the
Retirement System to the Pension System and not "on acc…
IRCCourt RulingsSep 19, 2019related by meaning
e. Because petitioner raises only a legal issue, we
decide whether he is liable for the deficiency without regard to the burden of
proof.
II. Analysis Gross income generally includes distributions from an IRA under the
provisions of section 72. Sec. 408(d); see Sears v. Commissioner, T.C. Memo.
2010-146. Section 72(t)(…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…actices
39,019,523
0.00
612.84
0.00
Update Proxy Voting Policies
4,877,440
0.00
76.61
0.00
Total
43,896,963
0.00
689.45
0.00
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsJul 24, 1996
…ployees:
Year Ended
Amount
1
June 30, 1988 $2,607,511
June 30, 1989
2
3,069,240
June 30, 1990 3,528,896
June 30, 1991 4,275,589
1
Because the VEBA Trust reimbursed
Provident for these payments, there is a
slight timing difference resulting from these
disbursements.
2
Expenses for July and August 1988
totaled $412,467.
…
IRCCourt RulingsDec 19, 1989related by meaning
was the only exception intended by Congress, since, had it intended any other, it would similarly have been specifically stated in the Code. We agree. Substantially the same argument made by petitioners was made and rejected in Sullivan v. Commissioner, 76 T.C. 1156 (1981), affd. by unpublished order (10th Cir. 1983). …
IRCCourt RulingsJan 24, 1962
….” Burson v. Huntington, 21 Mich. 415 (1870), 4 Am.Rep. 497; Salley v. Terrill, 95 Me. 553, 50 Atl. 896 (1901).
Accordingly, it is the opinion of this Court that the petitioner is not entitled to deductions in 1955 and 1956 for amounts purportedly contributed to its employees’ pension trust, since the contributions wer…
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 …
IRCCourt RulingsJun 9, 1965
… 84
Indiana unemployment compensa-tion_ 4, 316. 86
Indiana gross income. 29. 10
Local property- 18, 896. 04 81, 776. 43
108, 017. 79
Provision for vacation and holiday pay_ 27, 616. 51
Provision for contribution to pension fund. 17, 500. 00
Total current liabilities_ $248, 435. 97
Capital
Common stock — $10 par value; …
IRCCourt RulingsMay 17, 1973related by meaning
was “earned income” within the ambit of section 911 (b) and is excludable from gross income to the extent of $25,000 per year under section 911 ('a). Petitioner has claimed overpayments of $5,517 for 1965 and $7,040.82 for 1966. As to the first amount, it is stipulated that the petitioner overstated his gross income f…
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 …
IRCCourt RulingsSep 23, 2019related by meaning
titioner husband's testimony concerning the legitimacy and amount of the
business expenses was evasive and lacked credibility. For example, when asked whether he had brought documents to substantiate his business expenses, he
responded that his documents were too numerous for him to find those respondent
had requested …
IRCCourt RulingsFeb 28, 2024related by meaning
luded that
the bulk of the $26 million received by hi s IRA was attributable to his
relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…
IRCCourt RulingsMar 26, 1979
… v. United States, 364 U.S. 361 (1960), and its progeny. See, e.g., Salley v. Commissioner, 55 T.C. 896 (1971), affd. 464 F.2d 479 (5th Cir. 1972); Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th-Cir. 1971). In point of fact, there is no indication that Mary F. Minnis was borrowing against the annu…
IRCCourt RulingsFeb 25, 2014related by meaning
o rewrite a statute because they might deem its effects susceptible of
improvement."). While petitioner may perceive the result to be harsh, we cannot ignore the plain language of the statute, and, in effect, rewrite the statute to
achieve what she advocates as a more equitable result. See Eanes v.
Commissioner, 85 T.C…
IRCCourt RulingsFeb 15, 2002related by meaning
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…
79 FR 26838 — Tax Treatment of Qualified Retirement Plan Payment of Accident or Health Insurance Premiums IRCFinal Rules (FR)May 12, 2014
…R 46421). Corrections to the proposed regulations were published in Announcement 2007-98 (2007-2 CB 896). The Treasury Department and the IRS received written comments on the proposed regulations and a public hearing was held on December 6, 2007.
After consideration of the comments received in response to the proposed …
IRCCourt RulingsJan 27, 1998related by meaning
articipants, Harold Breslow and Robert Levine,
received their full benefit and petitioner signed an irrevocable
waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we
find no documentary evidence that all rank and file employees
were paid their full vested interest, especially …
IRCCourt RulingsMar 24, 1993
…y unavailable benefits or of continued work under the same conditions. Mitchell v. Mobil Oil Corp., 896 F.2d 463, 467 (10th Cir. 1990). The fact that an employee declining the early retirement offer may face the same risk of layoff as every other employee does not make acceptance of the offer coerced. Id.; Bodnar v. Sy…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…