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94 documents · 0.35sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2017-132 — Jack Howard Taylor v. Commissioner
    IRCCourt RulingsJul 5, 2017
    …r the 2012 taxable year. The case was submitted fully stipulated for decision without trial. M Rule 122.¹ Respondent determined a $3,806 deficiency in petitioner's Federal income tax for tax year 2012. Petitioner has conceded all adjustments, save for the inclusion in taxable income of an additional $32,505 in benefits…
  2. 140 T.C. No. 12 — Lawrence F. & Sara L. Peek v. Commissioner
    IRCCourt RulingsMay 9, 2013
    … 4973. - 4 - FINDINGS OF FACT These cases were submitted by the parties fully stipulated under Rule 122 for decision without trial,3 and the stipulated facts are incorporated herein by this reference. Abbot Fire & Safety, Inc. In 2001 Mr. Fleck identified Abbott Fire & Safety, Inc. ("AFS"), as an attractive business op…
  3. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  4. 122 T.C. No. 16 — Gregory Iannone v. Commissioner
    IRCCourt RulingsApr 19, 2004
    122 T.C. No. 16 UNITED STATES TAX COURT GREGORY IANNONE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17412-02L. Filed April 19, 2004. P filed a timely petition for judicial review pursuant to sec. 6330(d)(1)(A), I.R.C., in response to a notice of determination by R to proceed with collection …
  5. 74 T.C. 873 — Thompson v. Commissioner
    IRCCourt RulingsJul 30, 1980related by meaning
    cation under section 401(a). See also secs. 1.410(a)-l(a) and 1.411(a)-(l)(a), Income Tax Regs.; H. Rept. OS-SOT (1974), 1974-3 C.B. (Supp.) 236, 343. In any event, due to the effective date provisions, section 412 applies to no Central plan year which had ended when the favorable determination was made. In the case of…
  6. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    988, $110,000 for its fiscal year 1989, $122,500 for its fiscal year 1990, and $215,000 for its fiscal year 1991. For its fiscal year 1988 Animal Fair paid Mr. Richard Duff $103,750 and Mr. Dean Fitch $156,922 for service for three-quarters of the year, and Mr. William Jeurgens - 13 - $122,047. For its fiscal year 1989…
  7. T.C. Summary Opinion 2015-60 — Cheryl Lynn Ireland v. Commissioner
    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…
  8. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  9. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  10. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …r than $40,000. See Marre v. United States , 38 F.3d 823, 828-829 (5th Cir. 1994); United States v. 122.00 Acres of Land , 856 F.2d 56 (8th Cir. 1988) (applying sec. 304(a)(2) of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, 42 U.S.C. sec. 4654(a); fees were not actually "incurre…
  11. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004
    122 T.C. No. 5 UNITED STATES TAX COURT ESTATE OF JOHN W. CLAUSE, DECEASED, THOMAS Y. CLAUSE, PERSONAL REPRESENTATIVE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12995-01. Filed February 9, 2004. P, prior to his death, sold all of his shares in C to C’s employee stock ownership plan in 1996. …
  12. 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…
  13. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …ravelers 420,000 -0--0--0- Deposit by petitioner 100 19,808 (976) -0--0- Investment income -0--0-41,122 40,531 Total 2,186,918 1,420,581 1,017,531 132,399 1,310,132 Deductions: Benefits 420,136 1,060,659 930,761 1,483,491 1,012,141 Administrative expenses -0-95,197 54,780 78,030 186,391 Total 420,136 1,155,856 985,541 …
  14. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […