IRCCourt RulingsMar 5, 2018related by meaning
r I.R.C. sec. 4973.
He] : On the facts presented, Ps and not their Roth IRAs were
the owners, for Federal tax purposes, of the FSC stock; in substance the FSC dividends were income to Ps, who contributed the funds to
their Roth IRAs. Summa Holdings, Inc. v. Commissioner, 848 F.3d
779 (6th Cir. 2017), rev'g T.C. Memo. 2…
IRCCourt RulingsSep 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 6, 2013
…00, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010).
The Department of Health and Human Services reg…
IRCCourt RulingsJun 3, 2013related by meaning
T.C. Summary Jpinion 2013-42
UNITED STATES TAX COURT
ASTER TIRF E, Petitioner v.
COMMISSIONER OF INTE 1NAL REVENUE, Respondent
Docket No. 25865-10S. Filed June 3, 2013.
Aster Tirfe, pro se.
Steven Roth, for respondent.
SUMMARlY OPINION
CARLUZZO, Special Trial Judge This case was heard pursuant to the
provisions of sect…
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…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction IRCFinal Rules (FR)Aug 28, 2026
…5-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Pub. L. 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Pub. L. 111-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029;
( printed page 55465)
Division M, Pub. L. 113-235, 128 Stat. 2130; Pub. L. 116-260, 134 Stat. 1182; Secretary of Labor's O…
IRCCourt RulingsDec 2, 2010related by meaning
bility for income tax for
2004 that exceeded $1,000, net of any section 31 credit, and has
taken judicial notice of the fact that petitioner had a tax liability in 2003. Therefore, the Court sustains respondent's
determination of the addition to tax pursuant to section 6654(a).
The Court has considered all of petitione…
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
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…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
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…
IRCCourt RulingsOct 29, 2013related by meaning
s amount includes the additional tax of $32,137 under sec. 72(t).
- 27 -
[*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec.
1.6664-4(b)(1), Income Tax Regs.
The parties have agreed in the stipulation of settl…
IRCCourt RulingsMay 14, 2012related by meaning
etitioner does not cite any relevant law to establish her position. We
similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of
section 61, that all income is taxable unless explicitly excluded. See Baldwin v.
Commissi…
IRCCourt RulingsJan 2, 2020related by meaning
n 72(t) imposes an additional 10% tax on early distributions from a
qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not
attained the age of 59½ when she received the distributions at issue. The IRA
distribution…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
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…
IRCCourt RulingsFeb 20, 2003related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 1999,
the taxable year in issue.
T.C. Summary Opinion 2003-13
UNITED STATES TAX COURT
MARK F. BENEVENTI, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1558-02S. Filed February 20,2003.…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…