IRCCourt RulingsJul 26, 1989related by meaning
OPINION
COHEN, Judge:
Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
IRCCourt RulingsSep 15, 2005related by meaning
tax status,
it should also have jurisdiction over section 6652(c) (1) for
purposes of section 6330(d)(1):
This [Court] has jurisdiction to adjudicate whether a tax ehempt organization has unrelated
business taxablþ income pursuant to IRC §512, as well
as to determine any penalties in connection with such
an assertion,…
IRCCourt RulingsAug 3, 1987
…ned on the basis of the specific facts and circumstances involved. Simpson v. Commissioner, 64 T.C. 974, 984 (1975); Ellison v. Commissioner, 55 T.C. 142, 152 (1970); Hand v. Commissioner, 16 T.C. 1410, 1414 (1951). Sec. 31.3121(d)-l(c)(3), Employment Tax Regs. While the cases which deal with the common law factors usu…
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
…: 03/03/14
.015 service: 5
.0175 service: 5
.02 service: 13.5
Average salary: $53,121.00
Total: $22,974.83
Total/month: $1,915.00; deferred
Total federal/month ÷ total/month: 0.0 (at time of retirement)
Example 7: Disability Occurs After Eligibility for Optional Retirement
IRCCourt RulingsMar 30, 1978
…, and (7) the relationship the parties believe they are creating. [Simpson v. Commissioner, 64 T.C. 974, 984-985 (1975).]
The following additional factors have also been considered:
(1) The manner of payment, by the job or by the hour.
(2) Skill required.
IRCCourt RulingsAug 30, 2006related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
T.C. Summary Opinion 2006-136
UNITED STATES TAX COURT
LARRY J. AND CATHERINE E. FRANCE, Petitioners v
.
COMMISSIONER…
IRCCourt RulingsJun 14, 1993related by meaning
f the lump-sum distribution, to the extent it is otherwise includable in the taxpayer’s gross income for such taxable year. Secs. 402(e)(3), 62(a)(8). No change was made in petitioners’ gross income for the taxable year 1987 in the notice of deficiency, but petitioners’ tax liability was increased because respondent de…
PLR 200005001 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsFeb 4, 2000
… wrongful ... regardless of the terminology employed by the legislature.” In re Kline
, 403
F.Supp. 974, 978 (D.Md.1975), aff’d
, 547 F.2d 823 (4
th
Cir. 1977).
history. H.R. Rep. No. 93-807, p.28 (1974) (“...For this reason, the bill places the
obligation for funding and the penalty for underfunding on the person on w…
IRCCourt RulingsDec 2, 2013related by meaning
T.C. Summary Opinion 2013-96
UNITED STATES TAX COURT
SAMUEL BRACH AND LILLIAN BRACH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15460-12S. Filed December 2, 2013.
Ronald Jay Cohen, for petitioners.
Gennady Zilberman, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was h…
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…
PBGCPBGC Opinion LettersSep 28, 1994
…
are past
due ." H .R. R ep. N o. 93 -128 0, 93 d C ong., 2 d Se ss. 365 (19 74) , reprin ted. in 1 974 U.S .C.C .A.N . 503 8, 51 45.
n2
However, for si ngl e-empl oyer post -1987
plan years,
premi ums ( and any rel ated int eres t an d penal ti es) may not
be
paid
fr om
plan ass ets for any plan year begi nni ng wi th…
IRCCourt RulingsDec 11, 1997related by meaning
o be
treated as an amount received as a loan on the date of such
renegotiation, extension, renewal, or revision. TEFRA, sec.
236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2)
if it (1) is in an amount not exceeding a prescribed ceiling that
in no event may be more than $50,000, …
87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCProposed Rules (FR)Proposed May 5, 2022
…nuity of $100,000 payable at the end of each year for 13 years certain is $100,000 times 9.7423 or $974,230. The remaining amount is $25,770. Of the initial transfer amount, $25,770 is not needed to make payments for 13 years, so this amount, as accumulated for 14 years, will be available for the final payment. The 14-…
IRCCourt RulingsMar 5, 2018related by meaning
eded petitioners' contribution limits under section 408A and were
therefore excess contributions subject to section 4973 excise taxes for the years at issue, 2002-07. Consequently, the determinative question is whether the payments
- 21 -
from the FSC to the Roth IRAs were "contributions" under sections 408A and
4973.¹…
ERISAProposed Rules (FR)Proposed Sep 15, 2021
…ets
Total
Single- employer plans
Multiemployer plans
Multiple- employer plans
Total Plans
19,442
18,974
134
334
None or not reported
50
50
$1-24K
221
220
1
25-49K
183
182
1
50-99K
312
306
2
4
100-249K
816
800
3
13
250-499k
1,276
1,260
2
14
500-999K
2,561
2,522
4
34
1-2.49M
6,158
6,049
3
106
2.5-4.9M
4,790
4,683
7
100
5…
IRCCourt RulingsMar 4, 2010related by meaning
taxable portion of his
distribution from a qualified retirement plan in 2003 . Section
72(t)(1) generally imposes, subject to various exceptions under section 72 ( t)(2), a 10-percent additional tax on earl y
distributions from a qualified retirement plan . Petitioner
reported t he distribution on his Form 4852 , there…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
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 RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…