IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsOct 29, 2013
…and CST of $9,754, while Mrs. Ellis had wage income
from an unrelated employer in the amount of $40,579.
15This loss consisted of the $1,799 allocable to Mr. Ellis and the $450
allocable to Mrs. Ellis out of CDJ's net loss of $3,598 for tax year 2005.
(continued...)
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[*10] On the return, petitioners also reported…
IRCCourt RulingsJul 21, 2008
…t
for any other case .
Respondent determined a deficiency in petitioners' Federal
income tax of $28,579, as well as an accuracy-related penalty
under section 6662(a) of $3,555 .80, for the taxable year 2004 .
.The-issues for decision are : (1) To what extent th e
distributions received from Ms . Tilley's section 401(k)…
IRCCourt RulingsMar 31, 1970related by meaning
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
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 RulingsApr 2, 2024
…provide for a postponement period that is mandatory.
See Kingdomware Techs., Inc. v. United States, 579 U.S. 162, 172 (2016)
(“When a statute distinguishes between ‘may’ and ‘shall,’ it is generally
clear that ‘shall’ imposes a mandatory duty.”); see also Antonin Scalia &
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsJul 9, 1997
…g tax years 1988 and 1989, petitioners had
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rental income from the timeshares of $3,480 and $3,579.36,
respectively.
Prior to the purchase of the timeshares, petitioner had some
previous experience with owning rental property. Petitioner had
purchased a condominium on Cape Cod, Massachusetts, in 1985, and
sold it …
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsJul 2, 2002
…. Coborn v. Commissioner
, T.C. Memo.
1998-377 (citing Am. Offshore, Inc. v. Commissioner
, 97 T.C.
579, 593-594 (1991)), affd. 205 F.3d 1345 (8th Cir. 1999).
Petitioner must establish sufficient objective facts from which
worthlessness could be determined. Fox v. Commissioner
, 50 T.C.
813, 822-823 (1968), affd. per c…
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 RulingsApr 3, 2002
…nefits
Program. Beginning in February 1997, petitioner began receiving
monthly pension checks of $5,579.83 from the University of
California totaling $61,378.13 for the year (the pension
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distribution). Of the total pension distribution for 1997,
$335.39 of this amount, i.e., $30.49 per month for 11 months, was