IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsMar 31, 2015related by meaning
…d and balanced decision, the Court will not reweigh the
equities. Id.; Lipson v. Commissioner, T.C. Memo. 2012-252, at *9 (citing Fib
Below Sales & Mktg., Inc. v. United States, 497 F.3d 828, 830 (8th Cir. 2007)).
IRM pt. 5.14.1.4(4) (June 1, 2010) states: "Installment agreements must
reflect taxpayers' ability to pay …
IRCCourt RulingsMay 29, 1997related by meaning
…
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To reflect the foregoing,
Decision will be entere…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
ent and the IRS will publish for public availability any comment submitted electronically or on paper to its public docket.
V. PAPERWORK REDUCTION ACT The collection of information contained in this notice has been submitted to the Office of Management and Budget in accordance with the Paperwork Reduction Act (PRA) (44…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
IRCCourt RulingsJun 3, 1998related by meaning
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
Notice 2013-2 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesFeb 4, 2013
…Segment Rates
First Segment Second Segment Third Segment
1.62 4.40 5.45 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, 2012-36 I.R.B. 332, the first…
IRCCourt RulingsFeb 10, 1997related by meaning
… filed, and thus
become a part of the record. They are accordingly referred to in
this Supplemental Memorandum Opinion to the extent we deem it
necessary to do so to address arguments contained in petitioner's
Motion and Judicial Notice Motions.
- 4 -
Rule 201(f) of the Federal Rules of Evidence provides that
judicial …
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
f an income, estate, or gift tax treaty to which the United States is a party. Comments are requested by March 10, 2014.
Notice 2013–79 Notice 2013–79 This notice requests comments from the public on a proposed revision to Rev. Proc. 2006–9, the procedural guidance to taxpayers on filing advance pricing agreement (“APA…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsJun 13, 2017related by meaning
to the January 2007 letter and that the representations in the court
filing were true, we conclude that this information was not new information that could give this Court jurisdiction to consider his claim. The letter's primary
purpose was requesting a payout based on "the materiality of the submissions
* * * previous…
IRCCourt RulingsDec 19, 2000related by meaning
limitation would have
expired.
- 11 -
Nor does the fact that respondent had already issued
petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected
items notice of deficiency to petitioners for the same year. See
sec. 6230(a)(2)(C); Hemmings v. Commissio…
T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner IRCCourt RulingsOct 28, 2019
…collection action. Petitioner
concedes that she is liable for the overreported income tax withheld.
2012 Underpayment
In 2012 petitioner took an $11,000 taxable distribution from her section
401(k) retirement plan account, and intervenor took a $23,510 distribution from
his section 401(k) retirement plan account, $23,4…
IRCCourt RulingsApr 10, 2018related by meaning
JRN
T.C. Memo. 2018-49
UNITED STATES TAX COURT
STACEY S. MARKS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18520-16. Filed April 10, 2018.
Ray C. Mayo, Jr., for petitioner.
Donielle A. Hubbard, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge: Respondent mailed petition…
IRCCourt RulingsJul 11, 2017
ommissioner, T.C. Memo. 1995-421. Section 1.72(p)-1, Q&A-10(a), Income
Tax Regs., provides that ordinarily the failure to make any installment payment when due7 violates the substantially level amortization requirement. However, the
substantially level amortization requirement is not violated so long as a payment,
even…
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…
IRCCourt RulingsMar 1, 2016related by meaning
ion provisions allow for the correction of an error made in a
closed tax year by extending the limitations period up to one year from the date a
- 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v.
United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the
profit ou…