IRCCourt RulingsDec 14, 2009
…licy had net cash surrender values of
$78,293 .21 on May 28, 2000, $55,617 .96 on May 28, 2001,
$33,357 .02 on May 28, 2002, and $12,703 .22 on May 28, 2003 . By
November 28, 2003, the monthly statement had indicated that the
net cash surrender value had been diminished to $2,782 .25 .
On March 1, 2004, the insurer iss…
IRCCourt RulingsDec 23, 2008related by meaning
v .
Commissioner , 111 T .C . 250, 255 (1998) ; Milner v . Commissioner ,
T .C . Memo . 2004-111 ; Gallagher v . Commissioner , T .C . Memo . 200134 . We conclude that petitioner is liable for the $1,971 10percent additional tax on her early $19,706 IRA distribution .
Decision will be entere d
for respondent .
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…
IRCCourt RulingsOct 11, 1995related by meaning
T.C. Memo. 1995-492
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed October 11, 1995.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Jud…
IRCCourt RulingsJan 3, 2011
…2005.
- 11
requirements.4 On Octobere22 2004, t he American Jobs Creation
Act of 2004, Ptib. L. 108-357 sec. 811(a),41182 Stat. 157/5, became
law and instituted a new penalty for fallùre to -disclose a listed
transaction. See sec. 6707A.
On- Novemb¯er 17, 2004, Niche sentalettets to the employers
participating¿ in the …
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…n ,
petitioners reported wage income of $ 31,031, taxable interest of $377,
ordinary dividends of $ 357, taxable refunds of $927, and other income of
$2,000, resulting in an adjusted gross income of $ 34,692. Petitioners
reported Ms. Aldridge’s pension distribution of $97,921 on line 16a,
Total p ensions and annuities,…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
IRCCourt RulingsApr 24, 2017
…,
932-933 (8th Cir. 1999); Oren v. Commissioner, T.C. Memo. 2002-172, 84
T.C.M. (CCH) 50, 57, af[d, 357 F.3d 854 (8th Cir. 2004). Even if the notes did
have economic substance, it is questionable whether petitioners would receive a
basis increase where they in effect issued the notes to themselves without subjecting th…
IRCCourt RulingsJun 30, 2004related by meaning
nnuity described in section
408(b).” Sec. 7701(a)(37) (an individual retirement plan is
commonly referred to as an IRA). Section 72(t)(2)(E) was added by section 203(a) of the Taxpayer Relief Act of 1997, Pub. L.
105-34, 111 Stat. 788, 809. The Report of the Committee on the
Budget refers only to withdrawals from IRAs.…
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…
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…
IRCCourt RulingsJun 24, 1966
…. 22 1957 _ (36.80)
1951 _ 5, 642. 43 1958 _ 2,107.80
1952 - (15,291. 66) 1959 _ 6, 398.16
1953 _ 5,357. 65 1960 _ 1,874.59
1954 - (4,754. 95) 1961 _ 9,205.08
It had always been the consistent policy of petitioner to show concern for its employees and their families in cases of death, and to provide fringe benefits to …
IRCCourt RulingsApr 12, 1979related by meaning
e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
IRCCourt RulingsJul 6, 1998related by meaning
1
Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1998-247
UNITED STATES TAX COURT
HERMAN E. AND SHERI L. VILLARROEL, Petitioners v
.
COMMISSIONER OF INTERNAL…
IRCCourt RulingsMar 9, 2011related by meaning
s not contested any
part. of Mr. Renkel-'s account of the Transaction. Sincesthere is
no disagreement as to what happened, de do not see whyrdiscovery is necessary. Respondent's professed'need.for discovery is
nothing more than a fishing- expedition. As iwe have previously
warned: "tax cases are to be thoroughlysingest…
IRCCourt RulingsAug 13, 1990
… law. Pilot Life Insurance Co. v. Dedeaux, 481 U.S. 41, 51 (1987). In Colony, Inc. v. Commissioner, 357 U.S. 28, 36 (1958), the U.S. Supreme Court articulated the policy behind the predecessor to section 6501(e) as follows:
We think that in enacting section 275(c) Congress manifested no broader purpose than to give the…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011
…ion 6404(g) was amended by section 903(c) of the American Jobs Creation Act of 2004, Public Law 108-357 (118 Stat. 1418, 1652) (AJCA), enacted on October 22, 2004, and by section 303 of the Gulf Opportunity Zone Act of 2005, Public Law 109-135 (119 Stat. 2577, 2608-09) (GOZA), enacted on December 21, 2005. Section 8242…
IRCCourt RulingsAug 24, 1995related by meaning
spouse, child, or other dependent of a participant, and
(ii) is made pursuant to a State domestic relations law (including a community property law). “The reason that many ERISA sections have such counterparts in the IRC is that, to encourage employers to establish pension plans, Congress provides favorable tax treatme…
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…
3.1
Claim Denied
1.1
0.3
0.3
2.0
0.6
0.4
2.8
0.8
0.5
Post-Service:
Claims Approved
196.2
55.5
45.2
357.8
101.1
72.3
490.7
138.7
88.6
Claim Denied
36.2
10.2
9.0
66.0
18.7
14.3
90.6
25.6
17.6
Claim Extended
9.0
2.5
5.6
16.4
4.6
8.9
22.5
6.3
10.9
Total Internal Appeals (thousands)
85.4
24.1
52.8
155.7
44.0
84.5
213.6
60.…