IRCCourt RulingsNov 21, 2023
United States Tax Court
T.C. Memo. 2023-140
KUNJLATA J. JADHAV AND JALANDAR Y. JADHAV,
Petitioner s
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 12520-19. Filed November 21, 2023.
—————
Dustin R. Jeffords and Philip M. Anthony , for petitioner s .
Ardney J. Boland and Emile L. Hebert , for respond…
IRCCourt RulingsFeb 26, 2014
…d. at 121 (citing Dean v.
Commissioner, 57 T.C. 32, 44 (1971), Kaplan v. Commissioner, 21 T.C. 134, 140 (1953), Lanteen Med. Labs., Inc. v. Commissioner, 10 T.C. 279, 288 (1948), and
Elkins v. Commissioner, 12 B.T.A. 1058 (1928)).
Petitioners' case is not like Wood. The $36,000 was not in fact deposited
within the stat…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
IRCCourt RulingsApr 16, 2020
…Reported Disallowed Conceded At issue
Meals and entertainment $1,531 $1,531 --- $1,531
Rent/lease 4,140 4,140 $3,372 768
Depreciation 1,600 1,600 --- 1,600
Other expenses 1,707 1,707 1,707 ---
Car and truck 3,600 3,600 --- 3,600
Legal and professional 12,204 12,201 12,201 ---
Travel 14,785 14,785 14,785 ---
i. Meals an…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013related by meaning
amended.
List of Subjects
26 CFR Part 54
Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590 Continuation coverage
Disclosure
Employee benefit plans
Group health plans
Health care
Health insurance
Medical child support
Reporting and recordkeeping requirements
45…
IRCCourt RulingsAug 28, 2014
…ring 2011, shortly after losing his job with Synapse,
Mr. Matthews requested a distribution of $128,140 from his 401(k) plan account.
He understood that his loan would have to be repaid before he could receive a
distribution from the account. In this regard, Prudential applied $36,278 of
Mr. Matthews' accrued plan bene…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
IRCCourt RulingsJun 4, 1997
…the profit sharing fund to a
trust for the benefit of Mrs. Lozon in the amounts of $89 in 1990
and $140 in 1991. These amounts were vested when made. It is
also stipulated that Allstate made contributions under its
pension plan to a trust for the benefit of Mrs. Lozon and that
she was vested in the amounts of $13,193 i…
IRCCourt RulingsJun 1, 2009
…2000
2001
2003
2004
2005
Loan Prior Principal Repaymen t
Amount Amount Ter m
$5,110 -0- 10 year s
6,140 $3,147 .01 10 year s
5, 000 7, 694 .26 3 .77 year s
7,370 9,383 .36 3 .69 year s
7,180 .12,754 .46 5 years '
7,240 16,359 .31 5 year s
7,870 19,482,80 5 years .
7,520 22,439 .39 5 year s
9, 00,0 22, 521 .97 5 years .…
IRCCourt RulingsJan 27, 1998related by meaning
Inc.
, supra
at 160. In this case, the contribution of accounts
receivable presents concern over valuation and imposes collection
duties on the Plan. The assignment of the accounts receivable, whether they were
encumbered or unencumbered,
6
to satisfy the Corporation's funding
obligation under section 412 was a "sale …
IRCCourt RulingsFeb 4, 1998
…termined that petitioner should have reported
income as follows: For 1993, $69,805 in wages and $73,140 in net
capital gains;
2
for 1994, $33,183 in wages and $84,459 in taxable
- 4 -
2
(...continued)
capital gain as $73,140, based on petitioner's sale of property
at a sale price of $79,900 and a basis of $6,760. Respo…
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 RulingsMay 19, 2011
…ithin a period specified in that contract.
-5of the policy without regard to surrender charges was $140,901,
and the value of the policy after surrender charges was zero.
Petitioners received a 2003 Form 1099-R, Distributions From
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc.,…
PBGCRegulationsDec 7, 2023related by meaning
[Reserved]
IRCCourt RulingsMar 31, 2015
thin the discretion of the Commissioner. Thompson v. Commissioner, 140
T.C. 173, 179 (2013) (citing section 301.6159-1(a), (c)(1)(i), Proced. & Admin. Regs.). If a settlement officer follows all statutory and administrative guidelines
and provides a reasoned and balanced decision, the Court will not reweigh the
equitie…
71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner IRCCourt RulingsMar 19, 1979related by meaning
section 404(a)(7) and section 1.404(a)-13, Income Tax Regs., is reasonable and wé refuse to hold it invalid.
Decision will be entered under Rule 155. Petitioner has also agreed to an adjustment to its taxable income made by respondent for forfeitures not properly offset by petitioner against its allowable pension plan…
IRCCourt RulingsMay 9, 2013
6ob- 6u5ktF6cx)
140 T.C. No. 12
UNITED STATES TAX COURT
LAWRENCE F. PEEK AND SARA L. PEEK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
DARRELL G. FLECK AND KIMBERLY J. FLECK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5951-11, 6481-11. Filed May 9, 2013.
In 2001 Ps establish…
IRCCourt RulingsJul 29, 1997related by meaning
T.C. Memo. 1997-346
UNITED STATES TAX COURT
WILLIAM L. REESE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18442-95. Filed July 29, 1997.
1. Held
: P is taxable on a pension plan
distribution because he failed to roll over that
distribution within the 60-day period prescribed by
sec. 402(a)(5)…
IRCRegulationsJul 26, 2017related by meaning
(a)(3)(ii) (ii) An employer that owes the tax described in paragraph (a)(1) of this section must file the form prescribed by the Commissioner for the payment of the tax.
(a)(4) (4) Special rule for simplified employee pensions
(a)(4)(i) (i) An employer that maintains a simplified employee pension (SEP) as defined in se…