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90 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    ut instead continued to render services in the ongoing business. Rev. Rui. 81-26, 1981-1 C.B. 200, 201, superseding Rev. Rui. 73-414, 1973-2 C.B. 144. A revenue ruling of course merely represents the position of one of the litigants in this case, the Commissioner of Internal Revenue, and does not necessarily even repre…
  2. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan. Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
  3. T.C. Summary Opinion 2004-127 — Rowland Setyono v. Commissioner
    IRCCourt RulingsSep 13, 2004
    …tantiate the amounts of the deductions claimed. Sec. 6001; Meneguzzo v. Commissioner , 43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), (e), Income Tax Regs. With respect to certain business expenses specified in section 274(d), however, more stringent substantiation - 9 -
  4. PLR 200820009 — Investment in Contract
    IRCPrivate Letter RulingsMay 16, 2008related by meaning
    Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 200820009 Release Date: 5/16/2008 Index Number: 72.02-00, 72.20-00, 401.0000, 401.06-00, 402.00-00, 403.00-00, 408.06-00, 4973.00-00, 4979.00-00 -------------------------- ------------------------------------------------------------ ------…
  5. T.C. Memo. 2000-100 — Ronna Joan Robertson v. Commissioner
    IRCCourt RulingsMar 24, 2000
    …r to determine their correct tax liability. See sec. 6001; Meneguzzo v. Commissioner , 43 T.C. 824, 831-832 (1965); sec. 1.6001-1(a), Income Tax Regs. Moreover, a taxpayer who is claiming a deduction bears the burden of substantiating the amount and purpose of the item claimed. See Hradesky v. Commissioner , 65 T.C. 87…
  6. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  7. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    Penalty Year Deficiency sec. 6662(a) 2000 $347,369 $69,473 2001 341,566 68,313 2002 2,867,433 573,487 2003 12,869,823 2,573,965 2004 3,731,802 746,360 This case involves a complex set of transactions that give rise to five principal issues. For convenience, we will generally refer to Larry Austin and the late Arthur Ke…
  8. REG-141075-09 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 …
    IRCProposed Rules (FR)Proposed Jun 18, 2012related by meaning
    ce (or refraining from performance) of substantial services or on the occurrence of a condition related to the purpose of the transfer of shares to Q. Accordingly, none of section 83(c)(3), the imposition of the trading window by the insider trading compliance program and the potential liability under Rule 10b-5 preclu…
  9. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  10. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    ces, and, as passed through to him by the corporation, it became the basis for a deduction by the corporation under section 162(a)(1) 4 as "a - 10 - 4 (...continued) deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including-- (1) a reasona…
  11. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …he remainder of the payment to each of the Benenson Roth IRAs. Both Benenson Roth IRAs received $42,831, $221,776, $206,394, and $267,513 from JC Holding on January 18, April 23, July 25, and December 22, 2008, respectively. Both Benenson Roth IRAs received $17,765 from JC Holding on January 27, 2009. 5JC Export report…
  12. T.C. Summary Opinion 2015-60 — Cheryl Lynn Ireland v. Commissioner
    IRCCourt RulingsOct 1, 2015related by meaning
    ioner, 106 T.C. 337, 340 (1996) (citing and discussing the legislative history underlying section 408(f), the statutory predecessor to section 72(t)); Milner v. Commissioner, T.C. Memo. 2004-111. Section 72(t)(2)(B) provides an exception to the imposition of additional tax to the extent that retirement plan distributio…
  13. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004
    …papers, Inc. v. United 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 Co…
  14. 81 FR 21208 — Amendments to Class Exemptions 75-1, 77-4, 80-83 and 83-1
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    st that a reasonable person would conclude could affect the exercise of its best judgment as a fiduciary in rendering advice to the plan or IRA owner. For purposes of this section, a fiduciary acts in the “Best Interest” of the plan or IRA when the fiduciary acts with the care, skill, prudence, and diligence under the …
  15. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    …ith (Docket No . 14822-07) Accuracy-Related Penalt y Year Deficiency Sec . 6662(a) 2003 $64,157 $12,831 .40 Stephen and Roberta Mogelefsky (Docket No . 14917-07 ) Accuracy-Related Penalty Year Deficiency Sec . 6662(a ) 2003 $271,204 $S4,240 .80 The deficiencies are based on respondent's determination that the contribut…
  16. T.C. Summary Opinion 2012-103 — Gary Wayne Doolittle v. Commissioner
    IRCCourt RulingsOct 25, 2012related by meaning
    ernard v. Commissioner, 87 T.C. 1029, 1034 (1986); Loverin v. Commissioner, 10 T.C. 406 (1948); Stroud v. Commissioner, T.C. Memo. 1993-317; Lehrer v. Commissioner, T.C. Memo. 1980-256. The payments under the decree were displaced under sectioñ 71(b) by the lump-sum payment of the QDRO.3 See Bernard v. Commissioner, 87…
  17. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  18. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. - 9 - 5 See also …
  19. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    ies thereby created. We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
  20. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    … required by the Court's pretrial order. See G.J.B. & Associates, Inc. v. Singleton , 913 F.2d 824, 831 (10th Cir. 1990). In the Singleton case, the plaintiffs had not exchanged discoverable documents as required by the Court's pretrial order and sought to use the documents to refresh a witness' memory. The U.S. Court …