IRCCourt RulingsJan 20, 1982related by meaning
ee also Bogaards v. Commissioner, T.C. Memo. 1981-540; Boykin v. Commissioner, T.C. Memo. 1981-447. Cf. Alexander v. Commissioner, T.C. Memo. 1980-71. Petitioners have strenuously argued that the contribution to the IRA was deductible, while ignoring the inclusion by respondent of the income credited to the IRA in thei…
IRCCourt RulingsSep 25, 1996related by meaning
................................. 9
MIT 80.................................................. 12
Formation of MIT 80................................ 12 Investors in MIT 80................................ 13
Organization and Management of MIT 80.............. 13
MIT 80 Employee Leasing Arrangement................ 14
Oper…
IRCCourt RulingsMay 12, 1971
…his Court. In response Congress enacted section 44(d) of the Keren.ue Act of 1928, 45 (pt. 1) Stat. 806, which was designed to terminate the privilege of reporting gain on the installment method where a taxpayer who had elected installment method treatment subsequently disposed of unpaid installment obligations. The Ho…
IRCCourt RulingsJan 19, 2010related by meaning
from qualified
retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C .
Memo . 2 .005-124 (education expenses paid from a section .401(k)_ plan do not qualify for the exception . of ,section 72(t) (2) (E))- ;
Milner v . Commissioner , T .'C .` .Memo . 2004-111 (no "umbrell a
hardship exception" .for a distr…
85 FR 40834 — Improving Investment Advice for Workers & Retirees ERISAProposed Rules (FR)Proposed Jul 7, 2020
…f the business. This results in an hour burden of 4,340 [166]
and an equivalent cost burden of $718,806.[167]
The Department welcomes any comments about burden hours associated with producing an annual review report and certifying it.
Overall Summary
Overall, the Department estimates that in order to meet the condition…
IRCCourt RulingsJun 26, 2017related by meaning
t to "a former spouse * * * who is recognized by a domestic
relations order as having a right to receive" a share of the proceeds. See sec.
414(p)(8). Second, the distribution was not made "pursuant to a qualified domestic relations order." Although Jeremy's petition for dissolution of marriage requested a
50-50 divisi…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…
(a)
(b)
(c)
(d)
(e) = (c) * (d)
2020
634,155
291,711
$0.30
$87,513
2021
1,556,562
716,019
0.30
214,806
2022
3,055,474
1,405,518
0.30
421,655
IRCCourt RulingsMar 11, 1975
…Docket No. Petitioner Year Deficiency
524-73 Ronald C. Packard and 1968 Roma Jean Packard 1969 $696 806
525-73 Floyd L. Packard and 1968 Alice E. Packard 1969 618 760
526-73 H. Von Packard 1968 305
Sheila D. Packard 1968 308
H. Von Packard and Sheila D. Packard 1969 626
The' sole issue presented for decision is whether…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
IRCCourt RulingsSep 29, 1992
…61.00 5,303.00
12/31/87 2,647.00
12/31/88 1,802.00
15473-91 12/31/87 8,105.00 $2,026.25
12/31/88 10,806.00 2,701.50
Arizona Orthopedic
Institute of Traumatic and Reconstructive Surgery, P.C. 19654-90 04/30/87 139,909.00 32,699.00
12/31/87 45,507.00 2,623.00
Jonathan R. and Renee K. Fox 19716-90 12/31/86 13,750.00 4,125…
IRCCourt RulingsAug 13, 1990
…691 1,564 174
Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $181,806.
Although petitioners’ motion suggests that we lack jurisdiction over years closed by the applicable limitations period, we have jurisdiction over such years, as the statute of limitations is an affirmative defense t…
ERISADOL Technical ReleasesApr 1, 2026
…e out ERISA plans for special treatment. De Buono v. NYSA-ILA Med. & Clinical Servs. Fund, 520 U.S. 806, 814-15 (1997) (collecting cases). But conversely, the Supreme Court has held that ERISA does not preempt laws that require one-time severance payments,(16) PBM rate reimbursement regulations with only incidental eff…
IRCCourt RulingsJul 29, 1997related by meaning
T.C. Memo. 1997-346
UNITED STATES TAX COURT
WILLIAM L. REESE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18442-95. Filed July 29, 1997.
1. Held
: P is taxable on a pension plan
distribution because he failed to roll over that
distribution within the 60-day period prescribed by
sec. 402(a)(5)…
IRCCourt RulingsSep 24, 2007related by meaning
him . On May 24, 2002,
SBC Communications, Inc ., issued a check to petitioner in the
amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and
$3,367 .11 in California State income tax had been withheld .
During 2002, petitioner also received $9,552 …
IRCCourt RulingsMay 19, 2011related by meaning
treated as a gift, dividend,
contribution of capital, payment of compensation, or other
payment depending on the substance of the transaction. Section 7872 applies to a transaction that is a loan subject to a belowmarket interest rate and is described in one of several
enumerated categories. Sec. 7872(c) (1), (e) (1), …
IRCCourt RulingsJul 11, 2024related by meaning
fits fall
under section 104 , or any other specific statutory exclusion , Mr. Tuma
instead seems only to have argue d for a general exclusion based on disability for which he provides no support in the Code and for which we
have found none .
11
We have previously held both railroad retirement
and Social Security benefi…
IRCCourt RulingsJul 22, 1980related by meaning
ave specified, petitioner’s arrangements were vague and did not provide the employees with nonforfeitable rights to particular portions of the moneys. In reliance on the above, it follows that section 404(b) is inapplicable to petitioner, and accordingly, petitioner cannot deduct the $16,123 “contribution” pursuant to …
71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner IRCCourt RulingsMar 19, 1979related by meaning
section 404(a)(7) and section 1.404(a)-13, Income Tax Regs., is reasonable and wé refuse to hold it invalid.
Decision will be entered under Rule 155. Petitioner has also agreed to an adjustment to its taxable income made by respondent for forfeitures not properly offset by petitioner against its allowable pension plan…
IRCCourt RulingsJun 3, 1998related by meaning
ition is logically inconsistent
to the extent that it continues to treat the loan as
- 27 -
outstanding for purposes of section 72(p) despite the fact that the principal amount of the loan previously has been
deemed distributed and included in the taxpayer's income
under section 72(p). Furthermore, respondent cites no
…