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86 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 88 FR 82796 — Long-Term, Part-Time Employee Rules for Cash or Deferred Arrangements Under Section 401(k)
    IRCProposed Rules (FR)Proposed Nov 27, 2023
    …d the IRS released Notice 2020-68, 2020-38 IRB 567, which includes guidance with respect to section 112 of the SECURE Act. Q&A C-1 of Notice 2020-68 explains that, although section 112(b) of the SECURE Act excludes 12-month periods beginning before January 1, 2021, for purposes of determining an employee's eligibility …
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  3. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ce 2002-8 supra,-are unrêasonable or incorrect. Furthermore, on a motion f r summary judgm t thàt is prð];>erly'm de and supported, the o poeing party must 9et forth specific facts showing that there is a genuine issue fo trial. Rule 121(d) . Petitioner does not allege thathe has any evidence that wo ld sat-isfy 'that …
  4. IRCRegulationsJul 26, 2016
    …2.6 2.4 2.3 110 3.8 3.6 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Surviv…
  5. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …70 271,94 1 5 271,941 25,000 246,941 20,755 267,69 6 6 267,696 25,000 242,696 20,416 263,11 2 7 263,112 25,000 238,112 20,049 258,16 1 8 258,161 25,000 233,161 19,653 252,81 4 9 252,814 25,000 227,814 19,225 247,03 9 10 247,039 25,000 222,039 18,763 240,80 2 11 240,802 25,000 215,802 18,264 234,06 6 12 234,066 25,000 2…
  6. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  7. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    … purposes of the sec. 6651(a) addition to tax, petitioners are entitled to take into account the $1,112.23 income tax withholding shown on petitioner-husband’s Form W-2 (sec. 6651(b)). Respondent apparently has not taken into account for this purpose the 1977 estimated tax payment of $316.42 shown on petitioner’s Form …
  8. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  9. IRCRegulationsDec 30, 2016
    …ive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, Public Law 112-9 (125 Stat. 36 (2011)), the Department of Defense and Full-Year Continuing Appropriations Act, 2011, Public Law 112-10 (125 Stat. 38 (2011)), and the 3% Withholding Repeal and Job Creation Act, Public Law 112-56 (12…
  10. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  11. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …34 2,234 --- Interest 3,109 3,109 3,109 --- Insurance 10,634 10,634 10,634 --- Commissions and fees 112,432 112,432 112,432 --- i. Other Expenses On brief respondent concedes that petitioners have substantiated all but $170 of this reported expense. After careful review of the record, we find that petitioners substanti…
  12. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    of Pub. L. 104-106, 110 Stat. 521 (36 U.S.C. 5522); Sec. 890.112 also issued under section 1 of Pub. L. 110-279, 122 Stat. 2604 ( printed page 51769) (2 U.S.C. 2051); Sec. 890.113 also issued under section 1110 of Pub. L. 116-92, 133 Stat. 1198 (5 U.S.C. 8702 note); Sec. 890.301 also issued under section 311 of Pub. L…
  13. 74 T.C. 651 — Judd v. Commissioner
    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…
  14. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    … Plan The Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. No. 105-206, 112 Stat. 685, as pertinent to this case, added section 402(c)(4)(C). Section 402(c) provides general rules applicable to rollovers from exempt trusts. Section 402(c)(4) defines the term "eligible rollover distribution".…
  15. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    125 T.C. No. 5 UNITED STATES TAX COURT SERVICE EMPLOYEES INTERNATIONAL UNION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent 100 OAK STREET CORPbRATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 . saan. Ps are qualified labor. organi…
  16. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …"-0-". - 9 - [*9] 1994 23,331 -01995 25,885 -01996 1 26,500 -01997 26,500 -01998 i 26,500 -01999 26,112 3,112 2000 J 25,072 19,669 2001 25,011 26,000 2002 } 129,030 130,000 Total 512,985 315,699 The corporation did not begin to cover its expenses and was losing money until the Fletchers had owned it for 18 months. The …
  17. T.C. Memo. 2006-106 — Susan F. Mostafa v. Commissioner
    IRCCourt RulingsMay 15, 2006
    …e's gross income as provided in section 72. Sec. 408(d)(1); Lemishow v. Commissioner, 110 T.C. 110, 112 (1998). However, "rollover contributions" are not includable in gross income. Sec. 408(d)(3); Lemishow v. Commissioner, supra at 112. To qualify as a rollover contribution, the.IRA distribution must be rolled over in…
  18. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  19. 79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage
    IRCFinal Rules (FR)Feb 12, 2014
    …ive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011, Public Law 112-9 (125 Stat. 36 (2011)), the Department of Defense and Full-Year Continuing Appropriations Act, 2011, Public Law 112-10 (125 Stat. 38 (2011)), and the 3% Withholding Repeal and Job Creation Act, Public Law 112-56 (12…
  20. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .