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89 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    ficiency for the years in issue. Respondent determined that petitioner was liable for additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also determined that petitioner was liable for additions to tax under sections 6651(a)(1) and 6654(a), as set out ab…
  2. T.C. Summary Opinion 2005-78 — Hossam Helmy El-Bibany & Salma Hassan Kandil v. Commissioner
    IRCCourt RulingsJun 8, 2005
    …13, 60 (1995), affd. 140 F.3d 240 (4th Cir. 1998); Estate of Emerson v. Commissioner , 67 T.C. 612, 617-618 (1977); Megibow v. Commissioner , T.C. Memo. 2004-41; see also Lignos v. United States , 439 F.2d 1365, 1368 (2d Cir. 1971). The doctrine of equitable estoppel was raised for the first time by respondent on brief…
  3. IRCCourt RulingsAug 3, 1979related by meaning
    …x 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 Andrew Prebihalo . 290.20 Lorraine A. Heitchue . 379.96 Michael P. Grant and Mary Susan Grant . 318.82 P…
  4. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    w that there is a genuine dispute for trial that he had reasonable cause for not paying the unpaid tax on the 2013 return made for him by RA Landadio. C. Summary Judgment Rule 121(b) provides that, in the absence of a genuine dispute as to any material fact, and if a decision may be rendered as a matter of law, we must…
  5. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017related by meaning
    ent was ever amended, as required by section 1.72(p)-1, Q&A-3(b), Income Tax Regs. Moreover, petitioners' argument that the substance of what happened rather than the form of what happened should control ignores the express requirements of the loan agreement and applicable regulations. See sec. 1.72(p)-1, Income Tax Re…
  6. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  7. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    - *19. The Court did not make a determination regarding whether SO Taylor abused his discretion when he sustained the proposed levy. Because the Court determined that petitioner's underlying liability should be reviewed de novo at a future trial setting, the Court stated that a review of SO Taylor's administrative dete…
  8. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences 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. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
  9. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  10. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …20, 596 – 97, 601 (1983) ; and then citing Nat Harrison Assocs., Inc. v. Commissioner, 42 T.C. 601, 617 – 18 (1964) ) . We may make partial allocations to the extent “the evidence shows that neither side is correct.” Id . at 204 (first quoting Eli Lilly & Co. v. Commissioner , 856 F.2d 855, 860 (7th Cir. 1988), rev’g i…
  11. 73 T.C. 700 — Grant-Jacoby, Inc. v. Commissioner
    IRCCourt RulingsJan 16, 1980
    …bility of the contributions is governed by section 404(a)(5). In Educo, Inc. v. Alexander, 557 F.2d 617, 622 (1977), the Seventh Circuit, in reference to plans administered by Educo, stated that such plans “are clearly characterizable as deferred-compensation plans.” The issue before the Court of Appeals in that case w…
  12. 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…
  13. DOL Office of Administrative Law Judges — USDOL v. COMPGRAPHIX, INC
    ERISACourt RulingsOct 14, 1999
    … $343,000.00 and the obligation to provide services to all uncompleted contracts (estimated at ,075,617.00). (RX. C) 20. As additional consideration for the sale, Racom was to contribute all the capital necessary for the formation of Racom SW. 20,000 shares (twenty percent of the ownership) of Racom SW was to be distri…
  14. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …2004 return, the amount of the Wireless Distributors Inc. loss that the Goldbergs deducted was $645,617, without regard to basis. In their 2004 examination, the IRS disallowed the deductions claimed in excess of the Goldbergs' bases. The Goldbergs' S corporations participated in two benefit plans that gave rise to inco…
  15. 93 T.C. 79; 93 T.C. No. 8 — McManus v. Commissioner
    IRCCourt RulingsJul 24, 1989related by meaning
    eceiving from the IRS only the acknowledgment of the applications, two phone calls from Ms. Islas and the final adverse determination letters. OPINION Section 7476 creates a judicial remedy for taxpayers seeking determinations of qualification of retirement plans under section 401(a), which latter section lists the cha…
  16. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  17. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    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).…
  18. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    fter considering the statutory scheme, the regulations, and the legislative history, we grant respondent’s motion to dismiss for lack of jurisdiction. The statutory scheme supports respondent’s conclusion rather than petitioners’. Section 7476(b)(2) states that this Court may hold the pleading of any petitioner prematu…
  19. 79 FR 36387 — Debt Cancellation Contracts and Debt Suspension Agreements
    IRCFinal Rules (FR)Jun 27, 2014
    …Title 12 of the Code of Federal Regulations, parts 1 to 199, revised as of January 1, 2014, on page 617, in § 37.7, in paragraph (a), in the first sentence, “§ 37.6(d)” is corrected to read “§ 37.6(b)” and in the last sentence “§ 37.6(b)” is corrected to read “§ 37.6(d)”. [FR Doc. 2014-15113 Filed 6-26-14; 8:45 am] …
  20. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012related by meaning
    ditional tax provided by section 72(t)), penalties, and statutory interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record . 12 - does not establish that petitioners received a.notice of deficiency for 2007 and consequently a challenge to petitioners' 2007 tax liability is allowed in thi judicial p…