IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsApr 30, 2003
… (1988); Estate of Cowser v. Commissioner
, 736 F.2d 1168,
1171-1174 (7th Cir. 1984), affg. 80 T.C. 783, 787-788 (1983).
The Court will follow the statutory provisions governing the
issue in this case. With exceptions not applicable here, any
amount distributed from an IRA must be included in income by the
distributee …
IRCCourt RulingsNov 8, 1976related by meaning
n changing its name.
Decision will be entered for the respondent in docket No. 6797-74.
Decision will be entered under Rule 155 in docket No. 6798-74. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
Mr. Hebert is excluded from the computation because his salary …
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…ndscape Report, participants in small plans pay nearly double what participants in large plans pay.[783]
As such, small plans and their participants could see significant benefits from the protections provided in the amendments.
2. Comments From the Small Business Administration on the RFA
IRCCourt RulingsJul 27, 2004
…ten, see Estate of Cowser v.
Commissioner
, 736 F.2d 1168, 1171-1174 (7th Cir. 1984), affg. 80
T.C. 783, 787-788 (1983), and we may not rewrite the law because
we may “‘deem its effects susceptible of improvement’”,
Commissioner v. Lundy
, 516 U.S. 235, 252 (1996) (quoting
Badaracco v. Commissioner
, 464 U.S. 386, 398 …
IRCCourt RulingsDec 30, 1998related by meaning
of these funds since they
were originally invested in the Fortis annuity contract in 1992.
We conclude that petitioner's direct exchange of a portion of her Fortis annuity contract for a new Equitable annuity
contract qualifies under section 1035 and that no gain to
petitioner is to be recognized by reason of the exch…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
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…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
IRCCourt RulingsMar 9, 2011related by meaning
4 (1984); see United
States v. Mead Corp., 533 U.S. 218 (2001). Although they may be
entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not
decide whether Notice 2004-8, supra, should be given Skidmore
deference because the Transaction does not féll…
122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner IRCCourt RulingsFeb 9, 2004
…States
, 743 F.2d 781, 795 (11th Cir. 1984); Young v.
Commissioner
, 83 T.C. 831, 841 (1984), affd. 783 F.2d 1201 (5th
Cir. 1986). As we stated in Dunavant v. Commissioner
, 63 T.C.
316, 320 (1974): “We are not at liberty to infer that an
election existed when the unequivocal proof required by Congress
does not exist.”…
IRCCourt RulingsJul 24, 1996
…90:
Fiscal Years
1987
1988
1989
1990
Employer
contributions $42,000,000.00 -01
$40,737,374.59
2
$50,783,404.03
Employee
contributions -0- $ 1,555,626.86 1,841,554.51 2,505,955.35
Interest earned
3
773.98 1,749,030.80 78,641.10 -0Benefits paid -0- 39,153,640.83 48,808,587.03 53,289,359.38
Ending balance 42,000,773.98 6,…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax 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 And…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsApr 18, 1996
…
of adjusted gross income limitation, petitioners’ deduction for
miscellaneous expenses totaled $50,783.03.
6
The parties stipulated that Westech reimbursed
petitioner for at least $4,266.41 of his 1989 business expenses.
Petitioners’ 1989 Forms 1040 and 1040X
Petitioners claimed a $51,363.96
5
deduction for unreimburs…
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979related by meaning
ut the high cost of college education for their children. Dealing with the compensatory nature of the payments, the court said (570 F.2d at 212 n. 4): Section 61 defines gross income as “all income from whatever source derived,” including first of all “Compensation for services.” Section 83 provides that where property…
IRCCourt RulingsMar 24, 1980
…,185,666 989,516
Profit-sharing 58,595.30 96,206.43 139,191.71 175,510 146,153
Total 456,841.30 747,783.75 1,081,239.17 1,361,176 1,135,749
Andrew J. Homer
Salary $12,000.00 $12,000.00 $12,000.00 $12,000 $12,000
Commission 44,519.40 73,769.90 106,750.85 153,640 208,012
Bonus 5,651.94 8,576.99 11,875,09 17,984 21,910
To…
IRCCourt RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…
IRCCourt RulingsAug 22, 1994
…00 $37,000,000 Investment income 1,084,333 1,264,000 1,184,000
Total projected income 34,872,404 40,783,000 38,184,000
Anticipated expenses 29,303,726 32,800,000 36,736,000
Projected surplus 5,568,678 7,983,000 1,448,000
1987 VEBA Contributions
On December 22, 1987, the pension board approved a resolution to contribute…
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…