U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…s qualification was for the plan year ending March 31, 2001,
and all subsequent plan years.
¹'Forms 886-A sent to petitioner on March 7 and April 17, 2007, did not
contain any facts, law, or analysis with respect to petitioner's alleged failure to
timely amend the ESOP with the required sec. 414(u) language, instead li…
IRCCourt RulingsJan 3, 2011★ strong match
…the notice of deficiency will not
invalidate the notice . Sec 7522 (a) .
etitioner received a I orm 886-A, Explanation ofaItems,
accom anying his notice of deficiency.
2The F m 886.-A explains how3the IRS determined petitioner' s
defici ncy and states:
(. . . continued)
the Commissioner in the determination of the defi…
IRCCourt RulingsDec 13, 2012
…star 419 2003 contribution final
0098 Bank 12-29-04 1,523,133 Plan & Trust see Mr. Neumann
The Form 886-A also listed the three Schedules C referred to on Form 4549. The
Form 886-A then offered the following explanation with respect to respondent's
determinations:
I. Schedule C deductions disallowed
A. The deductions c…
IRCCourt RulingsApr 2, 2020
…rg made in his supplemental CDP hearing. For example, we cannot
determine the contents of the "Form 886-A" or the "reviewer's timeline" because
the "Form 886-A" is not in the record, and it is not clear that the "reviewer's
timeline" is in the record. And neither document's contents are described in the
record. However…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…589
$2,048
$460,359
$36,678
Per-Entity
$472
$2,331
$2,331
$29
$46,036
$1,183
Policies:
Total
$1,789,886
$7,232,234
$7,528,108
$76,028
$19,333
$59,932
Per-Entity
$961
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsMar 15, 2011★ strong match
… the required effective
(continued...)
- 4 -
On August 30,s 2007, respondent sent petitioner a Form 886-A,
Explanation of Items, which stated that in respondent's opinion
the plan had not been amended to reflect required statutory
changes. Respondent also explained his closing agreement
program."
On September 18, 2007,…
IRCCourt RulingsSep 15, 2005related by meaning
tinued...)
- 5 -
of the Secretary, and in the same manner as taxes. Sec.
6652(c) (4) (A).
Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to …
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…would have been $567,884 for BI's fiscal year 1988,
- 29 -
$888,742 for BI's fiscal year 1989, $996,886.40 for BI's fiscal
year 1990, and $287,010 for BI's fiscal year 1991. This
computation is as follows:
Income before 8-percent of 8-percent of
taxes of GSI income before income before
FY ended
& subsidiaries
taxes
tax…
IRCCourt RulingsDec 11, 2003related by meaning
oner
, supra
at 780.
11
See id.
at 773.
12
See Eckel v. Commissioner
, T.C. Memo. 1990-174.
13
See, e.g., In re Hatton
, 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang
, 164 F.3d 1029, 1033 (6th Cir. 1999).
section 6653(a),
3
section 6662,
4
section 6013,
5
section 6033,
6
section 6651(f),
7
section 6511,
8
sect…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
… 1 9 , 2018, she
submitted the NOPA to Team Manager Johnson for approval . The
NOPA referenced Form 886– A and stated that penalties would be
determined at the partner level. Team Manager Johnson signed the
NOPA on the same day and returned it to RA Zhao. RA Zhao compiled
the appraisal, the signed NOPA, and Form 886– A…
IRCRegulationsSep 9, 2016
…) $956 per month ($717 per month for survivor annuity) n/a. Joint and 100 percent survivor annuity $886 per month ($886 per month for survivor annuity) Approximately the same value as the QJSA. Lump sum $165,959 Approximately the same value as the QJSA. Age 60 Commencement Optional form Amount of distribution per $1,00…
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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…igations under ERISA and the governing plan documents.
See, e.g., Chesemore
v.
All. Holdings, Inc.,
886 F. Supp. 2d 1007, 1041-42 (W.D. Wis. 2012),
aff'd sub nom. Chesemore
v.
Fenkell,
829 F.3d 803 (7th Cir. 2016) (stating that when fiduciaries “lack the requisite knowledge, experience and expertise to assess the prude…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsFeb 28, 2024
….S.
213, 222 – 23 (1996); and then citing N.Y. & Presbyterian Hosp. v. United
States, 881 F.3d 877, 886 n.13 (Fed. Cir. 2018) (“[T]itles [in the Code]
have no legal effect . . . .”)), the legal rule of section 7806(b) does not
cause the word “assessment” to disappear from the amendment.
More importantly, in addition to…