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95 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-556 — A. C. Green Electrical Contractors, Inc. v. Commissioner
    IRCCourt RulingsDec 22, 1997
    … herein, respondent disallowed as excess contributions for 1987, 1988, and 1989, respectively, $177,505, $177,760, and $175,454 of the total claimed deductions relating to the plans. Also, for 1988, 1989, and 1990, respondent determined that petitioner was liable for excise taxes under section 4972 with regard to the p…
  2. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ble. Zmuda v. Commissioner , 79 T.C. 714, 727 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). In this instance, petitioner readily admits that A Atlantic is presently holding his property, and that there is a - 9 - 7 For the purposes of sec. 72(t), the term "employee" also refers to participants in individual retirement a…
  3. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
    IRCCourt RulingsJan 21, 1997
    …On their 1992 Federal income tax return (the 1992 return), petitioners reported gross income of $73,505.46 and adjusted gross income of $71,161.85. The income so reported consists primarily of petitioner's salary as a Nebraska district court judge. Mary Fuhrman was unemployed and received no compensation during 1992. O…
  4. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    articipants, Harold Breslow and Robert Levine, received their full benefit and petitioner signed an irrevocable waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we find no documentary evidence that all rank and file employees were paid their full vested interest, especially …
  5. T.C. Memo. 2012-195 — Neil J. Yosinski v. Commissioner
    IRCCourt RulingsJul 12, 2012
    …3. $46 as taxable interest 4. a capital loss of $3,000; 5. total income of $167,014; 6. tax of $27*,505; 7. an additional tax pursvant to section 72(t) of $16,743; 8. total tax of $44,248; 9. federal income tax withheld of $20; 10. credit for federal tele hone excise tax paid of $60; and 11. an amount owed (inci uding …
  6. 109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner
    IRCCourt RulingsDec 29, 1997
    …condemnation of property under eminent domain powers. See Lucas v. South Carolina Coastal Council , 505 U.S. 1003 (1992); United States v. Riverside Bayview Homes, Inc. , 474 U.S. 121 (1985); Agins v. City of Tiburon , 447 U.S. 255 (1980). Condemnation requires property to be taken against the taxpayer's will by a publ…
  7. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    … "the term 'equity denotes the spirit and habit of fairness and justness.'" Groseclose, 809 F.2d at 505 (quoting Gilles v. Dep't of Human Res. Dev., 521 P.2d 110, 116 n.10 (Cal. 1974) (quoting Black's Law Dictionary 634 (4th ed. 1957)). It further observed that "[t]he term conscience means 'the sense of right or wrong …
  8. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
  9. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    …gated and decided in a prior suit. Id. at 326 n.5; United States v. Intl. Bldg. Co. , 345 U.S. 502, 505 (1953); Meier v. Commissioner , supra at 282. In Megibow v. Commissioner , supra , this Court recently observed: From a legal standpoint, income taxes are levied on an annual basis, such that each year represents a n…
  10. T.C. Summary Opinion 2002-15 — Bryan K. Gauthier v. Commissioner
    IRCCourt RulingsFeb 15, 2002related by meaning
    tioner’s 1998 Federal income tax and an addition to tax under section 6651(a)(1) of $3,433 and $321, respectively. After concessions by the parties, 2 the issues are (1) whether petitioner is liable for the additional tax under section 72(t) and (2) whether petitioner is liable for the addition to tax under section 665…
  11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  12. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  13. T.C. Memo. 2001-118 — Roydell Campbell v. Commissioner
    IRCCourt RulingsMay 17, 2001
    …lated penalty imposed by section 6662(a). See Rule 142(a); Tweeddale v. Commissioner , 92 T.C. 501, 505 (1989). Petitioner argues that he relied on the 1997 version of IRS Publication 17 (Tax Guide for Individuals). The section regarding loans is as follows: - 9 - 3 The Rule 155 computation will take into account a For…
  14. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996
    …909,812,563 725,079,000 UFCW M W Pension Plan 22,500,268 21,053,791 Western Conf./Teamsters 647,156,505 500,960,586 *Actual contributions during the plan year as recorded on the Form 5500, Schedule B. The amount of total employer contributions actually paid to each of the CBA Plans based on hours and weeks worked by el…
  15. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014related by meaning
    contributions would have been taxable. CSRS does not provide for the - 12 - acceptance of rollovers. Because the payment was not accepted as a pretax contribution, it is taxable. See Montgomery, 18 F.3d at 500. Therefore, section 408(d)(3) does not apply and the $17,832 petitioner withdrew from his Fidelity IRA must b…