IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
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for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsJun 11, 1996
…or purposes of section 4980A(c), the aggregate amount of
petitioner's retirement distributions was $384,851.86; i.e.,
$378,053.86 plus $6,798. See sec. 4980A(e)(1), (c)(2).
In view of the foregoing, what is determinative in this case
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10
We note that petitioners did not elect 10-year forward
averaging under sec. …
146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner IRCCourt RulingsMar 29, 2016
…s by his or her IRA (an arrangement referred to as a self-directed IRA).3 Mr. Thiessen transferred $384,855.80 to the HIRA from his
Kroger retirement account, and Mrs. Thiessen transferred $47,220.61 to the WIRA
from her Kroger retirement account. Petitioners formally transferred these funds
(a total of $432,076.41) as…
IRCCourt RulingsFeb 3, 2016
…*7] 136 T.C. 569, 573 (2011) (slot machine winnings), rev'd and remanded on
other grounds, 722 F.3d 384 (D.C. Cir. 2013).
There may be some question as to whether the $1,000 of gambling winnings
had to be reported by the casino on an information return. The general threshold
for reporting a payment on an information re…
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
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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…
IRCCourt RulingsFeb 9, 2023
…40(f) of the Revenue Act
of 1926. H.R. Rept. No. 70- 2, at 20 (Dec. 7, 1927), 1939- 1 C.B. (Part 2) 384, 397 (“The
consolidated return is abolished in the bill for the taxable year 1929 and following
taxable years, and thereafter affiliated corporations are required to file separate
returns.”); S. Rept. No. 70-960, at …
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…
IRCCourt RulingsSep 14, 1993related by meaning
r in the computation of the sec. 72(t) tax, her petition raised the issue whether she should have been subject to any additional tax under sec. 72(t). Sec. 402(e)(1) has been redesignated sec. 402(d) by the Unemployment Compensation Amendments of 1992, Pub. L. 102-318, sec. 521(a) and (b), 106 Stat. 290, 300-310, 313, …
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsJan 16, 2002
… distributions 3, 822.50 12, 830. 00
Schedule C net income 7,652.50 (2,686.50)
Deductions
Medical 1,384.50 2,426.00
Mortgage interest 3,494.50 3,481.00
Charitable contributions 5,279.50 2,151.00
Taxes 308.50 87.50
Miscellaneous itemized 35.00 37.50
Other
Sec. 72(t) additional tax 382.00 1,283.00
Taxes withheld 1,144.00…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
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4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsAug 3, 1979related by meaning
155.
Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77.
Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue.
Respondent concedes …
IRCCourt RulingsJun 1, 2009related by meaning
account of the employee's disability ; (4) as part of a serie s
e for life ; (5) to a
employee after separation from service after attainment of ag A substantially equal periodic payments m
55 ; (6) as dividends paid with, respect to corporate stoc k
described in section 404(k) ; (7) to an employee for medica l
or (8)…
IRCCourt RulingsJun 21, 2011related by meaning
statement within 90 days. Therefore,
aRespondent argues that since the TSP did not accept
petitioner's late August payment, petitioner never made this payment. We base our holding on.the fact athat petitioner failed
to pay the remaining balance before the end of the cure period or
notify the TSP of his reinstatement.
-…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
g a portion of the claimed rebates. As respects the claim of the Georgia company the petitioner is before us as successor in interest of that company. The petitioner and the Georgia and Mississippi companies each held certificates of necessity covering emergency facilities and claimed amortization deductions with respe…