IRCCourt RulingsFeb 22, 1999related by meaning
lating to petitioners' loan,
10.5 percent is the fair market interest rate.
V. Addition to Tax
Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to
file Form 5330 for each taxable year, or portion thereof, in the
taxable period. Sec. 6011; sec. 54.6011-1(…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…inning of year)
a. Active $14.7 $38.5 $62.9 $83.6
b. Retired 28.2 36.7
47.7
48.9
c. Total 42.9 75.2 110.6 132.5
C. Accrued liability (beginning of year)
a. Active $12.6 $28.7 44.7 $59.4
b. Retired 28.2
36.7
47.7
48.9
c. Total 40.8 65.4 92.4 108.3
D. Normal cost (beginning of year) 0.3 1.2 2.5 3.3
E. Accrued liability (…
IRCCourt RulingsDec 19, 2016
… distribution from her IRA to make the
payment to Mr. Ozimkoski, Jr. Petitioner had the additional $110,000 in her IRA
because Wachovia incorrectly transferred the entirety of Mr. Ozimkoski, Sr.'s IRA
to her instead of to his estate. In light of all the circumstances, including her
experience, knowledge, and education,…
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…
IRCCourt RulingsApr 20, 2017
…iver. The only authority respondent cites in support
of this assertion is Bourekis v. Commissioner, 110 T.C. 20 (1998). Respondent's
reliance on Bourekis is misplaced.
Bourekis addresses this Court's jurisdiction to review a denial of a request
for abatement of interest. Under section 6404(h)(1), the jurisdictional pre…
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…
IRCCourt RulingsOct 17, 1995
…me tax
return, petitioners filed a Form 2119 with the following
information:
Selling price of home $110,000.00 Expense of sale 9,514.04
Amount realized 100,485.96
Basis of home sold 107,037.40
Gain on sale (6,551.44)
In response to the query "If you haven't replaced your home, do
you plan to do so within the replacemen…
IRCCourt RulingsDec 23, 2008related by meaning
v .
Commissioner , 111 T .C . 250, 255 (1998) ; Milner v . Commissioner ,
T .C . Memo . 2004-111 ; Gallagher v . Commissioner , T .C . Memo . 200134 . We conclude that petitioner is liable for the $1,971 10percent additional tax on her early $19,706 IRA distribution .
Decision will be entere d
for respondent .
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJul 25, 2012related by meaning
to the lesser of (1) 90% of the tax shown on the return for the
taxable year (or, if no return is filed, 90% of the tax for that year), or (2) 100% of the tax shown on the return, if any, for th preceding ta able year. Sec.
- 11 -
6654(d)(1)(B). Petitioner did not file Federal income tax returns for the taxable
years 2…
IRCCourt RulingsApr 24, 2017
Commissioner, T.C. Memo. 2015-123, 110 T.C.M. (CCH) 17, afD, 845 F.3d
555 (4th Cir. 2017). We there held, and the Court of Appeals agreed, that stock °The problem with Varde was apparently resolved six months later. In November 2003 the portfolios held by Rescomm were transferred to Holdings.
- 28 -
[*28] issued by an…
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…
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…
IRCCourt RulingsFeb 28, 2024related by meaning
8
years on June 10, 2016. That notice was issued timely because, as of
3
The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
IRCCourt RulingsApr 12, 2011related by meaning
here is substantial
authority for the taxpayer's treatment of an item if substantial
authority exists either (i) when the taxpayer files the return or (ii) on the last day of the taxable year to which the return
relates. Sec. 1.6662-4(d) (3) (iv) (C), Income Tax Regs.
The Browns cite several sources as substantial auth…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…