T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
tal wages. The regulations apply to all employers and others making supplemental wage payments to employees.
Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
IRCCourt RulingsJun 3, 1998related by meaning
or four year period" constituted a "revision
or modification of the [notes]" under State law. In
effect, petitioners argue that State law controls our determination of whether the subject loans were renewed,
renegotiated, modified, or extended after the effective
- 21 -
date of the 1986 Act. Petitioners cite no authori…
IRCCourt RulingsMar 5, 2018related by meaning
om a related supplier, the FSC is treated no differently for tax purposes
from the way it would be treated if it were a C corporation. See, e.g., sec. 921(d).44 Consequently, contrary to the dissent's suggestion, and far from being a
44For example, if a related supplier had no export income in a particular
year, the FS…
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
IRCCourt RulingsAug 23, 2010
…of $99
. The latter reported a
4
gross distribution of $2,977, consisting of a taxable amount of
$2,933 and a nontaxable amount of $43 . 3
Petitioner was under the age of 55 during 2005 .
In December 2005 the NYSLRS discovered that petitioner's
loans had been credited with three payments through payroll
deductions in J…
IRCCourt RulingsJun 29, 2015related by meaning
e parties agree that there is no genuine dispute as to any material
fact. After reviewing the pleadings and the comprehensive stipulation of facts and the attached exhibits, we conclude that a decision may be rendered as a matter of
law.
- 13 -
[*13] II. Statutory Framework
A. DISCs7
A DISC provides a mechanism for def…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsJul 22, 1999related by meaning
tates a penalty not to exceed
$25,000 if the taxpayer took frivolous positions in the
proceedings or instituted the proceedings primarily for delay. A position maintained by the taxpayer is "frivolous" where it is
"contrary to established law and unsupported by a reasoned,
colorable argument for change in the law." Col…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
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 RulingsJan 8, 2004
…years 1995 and 1996, respondent determined
deficiencies in petitioner’s Federal income taxes of $11,933 and
$26,947, additions to tax under section 6651(a)(1) of $2,927.50
and $5,347.57, and additions to tax under section 6654(a) of
$637.90 and $1,246.20.
After concessions by both parties, the issues remaining for
deci…
IRCCourt RulingsMay 14, 2009related by meaning
acknowledgmen t
of their alleged charitable contribution . See sec . 170 (f ) (8) (A) .
Accordingly, we hold that petitioners are not entitled to the charitable contribution deduction claimed on their 2004 Federal
income tax return .
Section 6673 Penalt y
Respondent requests imposition of a penalty pursuant to
section…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
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’ …
IRCCourt RulingsApr 24, 2017
…, having found the
notes to lack economic substance. Cf Bergman v. United States, 174 F.3d 928,
932-933 (8th Cir. 1999); Oren v. Commissioner, T.C. Memo. 2002-172, 84
T.C.M. (CCH) 50, 57, af[d, 357 F.3d 854 (8th Cir. 2004). Even if the notes did
have economic substance, it is questionable whether petitioners would rece…
IRCCourt RulingsSep 22, 1998related by meaning
te minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax und…
T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner IRCCourt RulingsMar 5, 2007
…ays reported tax due (including additions to tax for underpayment of estimated tax) of $11,131,
$14,933, $10,263, $2,114, and $6,252 for 1992, 1993, 1994, 1995,
and 1996, respectively. Petitioner knew that their taxes were
not being fully paid when the returns were filed, but intervenor
assured her that he would fully …
IRCCourt RulingsSep 24, 2007related by meaning
him . On May 24, 2002,
SBC Communications, Inc ., issued a check to petitioner in the
amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and
$3,367 .11 in California State income tax had been withheld .
During 2002, petitioner also received $9,552 …
IRCCourt RulingsMay 28, 1996
…payer acted in good faith.” Sec. 1.6661-6(b), Income
Tax Regs.; see also Vorsheck v. Commissioner
, 933 F.2d 757, 759
(9th Cir. 1991); Shelton v. Commissioner
, 105 T.C. 114, 125
(1995); Nestle Holdings, Inc. v. Commissioner
, supra
.
On the basis of these facts, we find that petitioner did act
as an ordinarily prudent…