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83 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    ified retirement plan during 2002, before he had attained age 59-1/2 . Thus, even if the additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imp…
  2. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    …hers constitute dividend income to Huffaker and House. Challenge Mfg. Co. v. Commissioner, supra at 663. In so doing we note that the minority shareholders had otherwise received dividends in Ma-Tran’s fiscal years 1972 and 1973. Issue 8. Additions to Tax Respondent determined that Ma-Tran owes an addition to tax under…
  3. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
  4. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    … Carter Mr. Horner 1971 $145,000 $92,000 $62,071 1972 159,500 97,520 65,720 1973 175,450 103,371 69,663 1974 192,995 109,573 73,843 1975 212,295 116,148 78,273 The Commissioner disallowed the deduction for nondeferred compensation in excess of such amounts and for the contributions to the profit-sharing plan attributab…
  5. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
  6. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  7. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    …,818,000 2019 4,309,000 13,410,000 4,766,000 709,000 23,194,000 2020 4,027,000 12,533,000 4,454,000 663,000 21,677,000 Total with 7% Discounting 412,183,000 Total with 3% Discounting 462,827,000 Note: The displayed numbers are rounded to the nearest thousand and therefore may not add up to the totals. e. Comments and R…
  8. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    es applicable t o annuity distributions from CRATs. Thus, to the extent sections 72 and 664 called for different treatment, section 664 would control. Second, section 7 2 do es not call for different treatment. Section 72(b)(1) allows an exclusion from income only to the extent the taxpayer has an “investment in the co…
  9. T.C. Memo. 2011-62 — Christy & Swan Profit Sharing Plan v. Commissioner
    IRCCourt RulingsMar 15, 2011related by meaning
    ner, T.C. Memo. 2005-70. Section 401(a) sets forth the requirements that must be met by a trust forming part of a profit-sharing plan in order for the trust to be eligible for favorable -tax treatment. Section 7476(a) confers jurisdiction on this Court to issue declaratory judgments as to the initial and continuing qua…
  10. T.C. Memo. 2016-182 — Dora Marie Martinez & Carlos Garcia v. Commissioner
    IRCCourt RulingsSep 28, 2016related by meaning
    ere made with post-tax dollars and thus no distributions would be taxable. She did not so testify. Petitioners allege that they spent more than $1,300 in qualifying tuition, as supported by a statement from their daughter's college, which they presented for the first time at trial. The statement was not received - 16 -…
  11. 89 FR 102735 — Disclosure of Records
    IRCFinal Rules (FR)Dec 18, 2024
    …such form and under such conditions as he may from time to time prescribe.” Free v. Bland, 369 U.S. 663, 667 (1962) (citing the predecessor to 31 U.S.C. 3105). Congress provided that the proceeds of savings bonds may be used by the Federal Government for any expenditures authorized by law. See31 U.S.C. 3105(a).
  12. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    tions and are administered in a manner identical to the manner in which the payments to article III judges in regular active service are administered. Accordingly, petitioners are not here receiving the double tax benefit Congress sought to prevent by section 219(b)(2)(A). Having decided that petitioners are entitled t…
  13. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. (b) Retroactivity of R…
  14. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    lowing statement: "It has been determined that you did not qualify as an organization exempt from tax under section 501 of the Internal Revenue Code.” On January 14, 1981, petitioner filed its petition herein for declaratory judgment seeking qualification of its retirement trust under sections 401 and 501 based on its …
  15. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  16. T.C. Memo. 1996-378 — Gaylord W. Greenlee v. Commissioner
    IRCCourt RulingsAug 15, 1996related by meaning
    c. Year 6651(a)(1) 1985 $ 813 1986 1,123 1987 1,403 1988 1,529 1989 1,581 1990 1,539 Then, in her reply brief, she conceded that the correct additions to tax are as stated in the text. The primary issue for decision is whether petitioner engaged in a prohibited transaction so as to be subject to the first-tier excise t…
  17. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  18. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    general tax credit (sec. 42), which apparently was taken into account by respondent in his assertion of an increased deficiency and additions to tax. Respondent concedes that, if the 32-page document filed by petitioners with respondent for 1977 constitutes an income tax return for purposes of sec. 6651(a), then the r…
  19. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…
  20. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    ng preincorporation years, can be recovered as compensation and deductible by a different taxable, entity, in years subsequent to his self-employment. As petitioner correctly points out in the instant case, unlike Bianchi, respondent bears the burden of proof. We believe, however, that respondent sustained his burden. …