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82 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  2. T.C. Summary Opinion 2010-72 — Ollie Marie Blade v. Commissioner
    IRCCourt RulingsJun 10, 2010
    …1040X capital gain dividends of $209, tax-exempt interest and tax exempt interest and dividends of $892, wages of $4,120, and .the 10-percent additional tax on early distributions from qualified retirement plans, which she claimed as a credit . 3 - After concessions by petitioner,' the issue remaining for decision is w…
  3. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    .a distribution of $6,277 from a qualified retirement . plan during~the'2001 tax year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that she qualified for any of the . exceptions in section 72(t)(2) . Accordingly ; we hold that Ms .-O'Boyle…
  4. T.C. Summary Opinion 2006-8 — Terry Fred Burnham v. Commissioner
    IRCCourt RulingsJan 26, 2006
    …ws: Additions to Tax Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a) $16,600 $3,735 $2,739 $892 After concessions, 1 the issues for decision are: (1) Whether a distribution of $20,102 petitioner received from the California Field Ironworkers Trust Funds (CFITF) is includable in gross income; (2) whether petitio…
  5. T.C. Summary Opinion 2009-156 — Dean Gochis v. Commissioner
    IRCCourt RulingsOct 13, 2009
    … . Id . ; Galt v . Commissioner , 216 F .2d 41,148 (7th Cir . 1954), affg . on this point 19 T .C . 892 (1953) ; Drake Univ . v . Commissioner , 44 T .C . 70, 72 ( 1965) . Petitioner owned the partnership interests in IEA an d Cronos . Although he irrevocably assigned the right to receive the income from those partners…
  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. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    e funds ) . 14 [* 14] Moreover, we disagree with petitioner that Larotonda was abrogated by the repeal of section 72(m)(4). Former section 72(m)(4)(A) was replaced by section 72(p) (1)(B), which is substantially similar to section 72(m)(4)(A). 7 In addition, this Court has continued to cite Larotonda as binding precede…
  8. T.C. Summary Opinion 2004-100 — Kurt Steven & Juanita Fay Urban v. Commissioner
    IRCCourt RulingsJul 27, 2004related by meaning
    7 (1989); Estate of Rosenberg v. Commissioner , 73 T.C. 1014, 1017-1018 (1980). Although we acknowledge that petitioners used the IRA distribution for laudable purposes, absent some constitutional defect we are constrained to apply the law as written, see Estate of Cowser v. Commissioner , 736 F.2d 1168, 1171-1174 (7th…
  9. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …of Amendment to deficiency answer Deficiency $1,117,383 $1,132,230 Sec. 6662(a) penalty 446,953 452,892 The increase in the deficiency results from respondent's determination to disallow the management fee deduction in full." Accordingly, respondent's adjustments, as amended, to Weekend Warrior's Form 1120 for 2002 are…
  10. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014related by meaning
    contributions would have been taxable. CSRS does not provide for the - 12 - acceptance of rollovers. Because the payment was not accepted as a pretax contribution, it is taxable. See Montgomery, 18 F.3d at 500. Therefore, section 408(d)(3) does not apply and the $17,832 petitioner withdrew from his Fidelity IRA must b…
  11. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013related by meaning
    m, or taxable event has been inconsistently subjected to two taxes; and (4) if the transaction, item, or taxable event involves two or more taxpayers, there is sufficient identity of interest between the taxpayers subject to the two taxes that the taxpayers should be treated as one. United States v. Dalm, 494 U.S. 596,…
  12. 57 T.C. 383 — Willie v. Commissioner
    IRCCourt RulingsDec 16, 1971related by meaning
    tion in an inservice training program, apparently identical to the program in the instant case, represent compensation for present or future services. In the case at bar, the pivotal question to be resolved in determining the taxability of the payments received by petitioner is whether the benefits derived from partici…
  13. 67 T.C. 411; 1 Employee Benefits Cas. (BNA) 2232 — Hill, Farrer & Burrill v. Commissioner
    IRCCourt RulingsDec 14, 1976
    …rying gradations of title or other relationship to property. Blumenfield v. United States, 306 F.2d 892, 899, 900 (8th Cir. 1962). Its meaning in a statute is affected by the context and the legislative purpose of the provision in which it is used. Blau v. Lamb, 314 F.2d 618, 620 (2d Cir. 1963). Given the congressional…
  14. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974
    …,044.15 . 0 54,586.17 Mar. 31,1968 Cash received 0 649.75 53,936.42 Mar. 31,1968 Cash received 0 17,892.27 36,044.15 Aug. 5,1968 Cash received 0 36,044.15 0 During the taxable years in issue, B-G’s cash account never went below $119,393.24, and was as high as $458,805.09. The average monthly balance for the period Marc…
  15. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    … Penalty Year Deficiency Sec. 6651 Sec. 6662(a) 1989 $16,298 -- $3,260 1992 47,758 -- 3,848 1993 62,892 $15,473 12,578 Prindle International Marketing, UBO Keyus Group - Trustee Addition to tax Year Deficiency Sec. 6651 1992 $32,508 $8,127 1993 54,068 13,517 We must decide the following issues: 1. Whether petitioners a…
  16. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    rs, as it was required to do. See Frederick Vietor & Achelis v. Salt’s Textile Mfg. Co., 26 F.2d 249, 255 (D. Conn. 1928); O.D. 419, 2 C.B. 60 (1920). What is more, petitioner claimed its foreign tax credit in dollars. It would thus appear that petitioner’s position should be rejected, since section 905(c) speaks in te…
  17. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …,057,021 $1,408,836 O Accrued liability: Active employees 652,308 1,710,610 2,362,918 CD Retirees 8,892,721 22,637,914 31,530,635 CO 05 00 9,896,844 25,405,545 35,302,389 Petitioner contributed $35,300,000 to the VEBA trust on December 29, 1986. Petitioner claimed a deduction for the full amount of the November and Dec…
  18. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    9950-92; W & A Payroll Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No. 3221-93; W & A Payroll Service, Bryen & Bryen, P.A., Tax Matters Partner, docket No. 10897-93; and Frank A. Pettisani and Lucille M. Pettisani, docket No. 23719-93. T.C. Memo. 1996-435 UNITED STATES TAX COURT BARRY B. BEALOR AND NANCY…
  19. DOL Office of Administrative Law Judges — USDOL v. COMPGRAPHIX, INC
    ERISACourt RulingsOct 14, 1999
    …r." See Final Regulation Relating to Civil Penalties Under ERISA Section 502(c)(2), 54 Fed. Reg. 26,892 (1989). The regulations for considering reasonable cause do not define the specific circumstances under which reasonable cause would exist and are sufficiently flexible to ensure that appropriate consideration is giv…
  20. U.S. Tax Court — Daryl L. Koelemay v. Commissioner
    IRCCourt RulingsSep 2, 2009related by meaning
    T .C . Summary Opinion .2009=i3 4 UNITED-STATES TAX COUR T DARYL L . KOELEMAY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 24773-08S . Filed September 2, 2009 . Daryl L . Koelemay, pro s e Ardney J . Boland III , for respondent . JACOBS, Judge : This case was heard pursuant to the provision…