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85 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
  2. T.C. Memo. 2011-62 — Christy & Swan Profit Sharing Plan v. Commissioner
    IRCCourt RulingsMar 15, 2011
    … Tax Relief Act of 2000 (CRA), appendix G of the Consolidated Appropriations Act, 2001, Pub. L. 106-554, 114 Stat. 2763 (2000), (...continued) the Internal Revenue Code (Code) applicable to the years before us, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2Petitioner's principal office …
  3. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    bed in section 72(t) in respect of Mr. Merrell's IRA distribution is sustained. As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case. We have considered similar claims in the past and have observed that there is no -8au…
  4. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    er husband and he was injured at the time of his early retirement, she should be taxed in the same manner as her former husband. A versiori of section 104(a)(1) allowing an injured person to exclude disability income from his or her taxable income has been in the Code since the Revenue Act of 1918 when it was added bec…
  5. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    ment provides A with notice of the specific amount of the liability and the basis for that liability as described in this paragraph (a)(7). Example 2. Taxpayer B is a partner in partnership P, a TEFRA partnership for taxable year 2005. B claims a distributive share of partnership income on B's Federal income tax return…
  6. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    IRCCourt RulingsApr 26, 2005
    …Pub. L. 105-206, 112 Stat. - 9 - 685; and the Community Renewal Tax Relief Act of 2000, Pub. L. 106-554, 114 Stat. 2763A-587. The IRS sent a copy of this determination letter to petitioner. After the pleadings were filed, petitioner filed a Motion for an Order to Calendar for Trial and a Motion for Permission for Disco…
  7. 89 T.C. 939; 89 T.C. No. 65 — Estate of Neisen v. Commissioner
    IRCCourt RulingsOct 28, 1987related by meaning
    1954 as amended and in effect at the time of decedent's death, and all rules referred to are rules of the Tax Court Rules of Practice and Procedure.↩ 2. The House committee report contains similar language. See H. Rept. 97-201 (1981), 1981-2 C.B. 352↩, 379-380. See also Staff of Joint Comm. on Taxation, General Explana…
  8. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    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…
  9. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …greements and restricted stock agreements almost identical to those in the instant case. See id. at 554. In particular, the taxpayers would receive less than full fair market value upon forfeiture of their stock if they did not perform substantial services for the S c orporation until the expiration of their initial te…
  10. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978related by meaning
    41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
  11. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …Investments 420,000 -0--0-923,755 1,626,112 Receivables due from employer 1,725,684 2,388,824 2,372,554 516,399 -0- Total assets 2,145,784 2,408,732 2,391,486 1,491,446 1,599,746 Liabilities: Unpaid claims 379,002 377,225 327,989 857,071 853,771 Net Assets 1.766,782 2.031.507 2.063.497 634,375 745,975 The financial sta…
  12. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    United States Tax Court T.C. Memo. 2024-6 CLAIR R. COUTURIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed January 17, 2024. ————— Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and Jonathan T. Amitrano , for petitioner. Hilary E. March , Laura A. Pr…
  13. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    … $42,000,000.00 -01 $40,737,374.59 2 $50,783,404.03 Employee contributions -0- $ 1,555,626.86 1,841,554.51 2,505,955.35 Interest earned 3 773.98 1,749,030.80 78,641.10 -0Benefits paid -0- 39,153,640.83 48,808,587.03 53,289,359.38 Ending balance 42,000,773.98 6,151,016.83 -0- -01 Represents the total of petitioner’s mon…
  14. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    …he Commissioner determined a deficiency in petitioners’ 1970 Federal income tax in the amount of $9,554.75 and addition to tax for the negligence penalty (sec. 6653(a), I.R.C. 1954) in the amount of $477.74. “Petitioner” shall hereinafter refer to petitioner Angelo J. Bianchi. The issues for decision are: (1) Whether p…
  15. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    act represents reallocated forfeitures, the parties may be able to handle the matter under Rule 155, if that can be done without reopening the record. The Nov. 9,1977, letter stated the reasons for the proposed adverse determination as follows: The final adverse determination letter, dated Mar. 28, 1979, stated in pert…
  16. 69 T.C. 773 — Lansons, Inc. v. Commissioner
    IRCCourt RulingsFeb 27, 1978
    … (1971); Liberty Machine Works, Inc. v. Commissioner, 62 T.C. 621 (1974), affd. per curiam 518 F.2d 554 (8th Cir. 1975); Babst Services, Inc. v. Commissioner, 67 T.C. 131 (1976); Wisconsin Nipple & Fabricating Corp. v. Commissioner, 67 T.C. 490 (1976), on appeal (7th Cir., June 27, 1977). See Ray Cleaners, Inc. v. Comm…
  17. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    s) earned in connection with the transactions covered by the exemption. Back to Citation 7.  67 FR 64137 (October 17, 2002). Back to Citation 8.   See Advisory Opinion 2011-08A (June 21, 2011). Back to Citation 9.  This proposal would move the definitions from Section I to Section VII. The other sections are re-ordered…
  18. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    vitt) deemed advisable, provided only that the principal of Trust A had first to be exhausted before payments of principal could be made from Trust B. At the death of the survivor of the decedent and his surviving spouse, the principal of Trust B and any unappointed portion of Trust A was to be distributed equally to M…
  19. PLR 200818018 — Substantially Equal Payments
    IRCPrivate Letter RulingsMay 2, 2008related by meaning
    Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 200818018 Release Date: 5/2/2008 Index Number: 72.20-04 ------------------------------------------------------------ - --------------------------- ---------------------------------- ------------------------------------ Third Party Communic…
  20. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971
    …ion of the accumulated funds from the trust. H. Kept. No. 1860, to accompany H.R. 9682 (Pub- L. No. 554), 75th Cong., 3d Sess., p. 46 (1938). In 1942, the pension trust provisions were revised extensively. The nondiscrimination requirements were established to deny qualification to a plan which “either cover[ed] only a…