IRCCourt RulingsSep 25, 2019related by meaning
appreciate the difficulties that incarceration imposed on petitioner in
obtaining information that might show that he had deductible expenditures for 2013 that exceed the $6,100 standard deduction accorded him by respondent,
petitioner has not--either in his defense to the motion or in his justification for his
two co…
IRCRegulationsJul 26, 2016
…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 Survivor Annuities; Two Lives—Expected Return Multiples Ages 105 106 107 108 109 110 111 112 1…
IRCCourt RulingsJun 6, 2019
…ty of the underlying tax liability is at issue, we review the
matter de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). A taxpayer may challenge the
4The term "Secretary" means the Secretary of the Treasury or his delegate.
Sec. 7701(a)(11)(B).
- 12 -
[*12] unde…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsMar 31, 2015
…herwise have an opportunity to
dispute the liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114 T.C. 604, 609 (2000). The phrase "underlying tax liability" includes the tax deficiency,
additions to tax, and statutory interest. Katz v. Commissioner, 115 T.C. 329, 339
(2000).
In determining whether to sustain the…
IRCCourt RulingsApr 20, 2017related by meaning
See Parker v. Commissioner, T.C. Memo. 2012-66, 103
T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax-
(continued...)
- 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to
assign error to any of respondent's determinations, asserting instead that he had no…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCCourt RulingsDec 30, 2013★ strong match
ss otherwise indicated, all section references are to the Internal
Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are
(continued...)
- 3 -
deficiency of $14,177 and an increased accuracy-related penalty of $3,435. A…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…n average, five minutes, resulting in an hour burden of 1,737,781 hours with an equivalent cost of $114,676,201.[82] Table 5—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Clerical
1,73…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
IRCCourt RulingsNov 21, 2007
…for
1998, 1999, and 2000 are summarized below :
1998 1999 200 0
Income :
1 Gross receipts or sales $114,634
2 Returns and allowances -03 Subtract line 2 from line 1 114,634
4 Cost of goods sold -05 Gross profit, subtract lin e
4 from line 3 114,634
6 Other income -07 Gross income . Add lines 5 and 6 114,63 4
Expenses :…
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 13, 2015related by meaning
claimed medical transportation expenses and that he falls under the
exception in section 72(t)(2)(B). As discussed supra Part II.A, petitioner is not entitled to deduct his claimed medical transportation expenses under section
213(a). Therefore, he does not fall under the exception in section 72(t)(2)(B) and
he is lia…
Notice 2024-3 — 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans IRCNoticesJan 8, 2024
… from defined contribution plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. These regulations are proposed to apply only on or after the date of publication of final regulations. The proposed regulations provide that, until the final regulations are published, an e…
IRCCourt RulingsSep 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 2026
… RMDs from defined benefit plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the amendments made by sections 114…
IRCCourt RulingsJan 29, 2019related by meaning
ents was this estimate, to which respondent reserved an objection on
grounds of relevance and authenticity. We overrule respondent's objection.
- 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets
to the extent of the gain from such sales or exchanges, plus the lower of:
(1) $3,000 o…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
… RMDs from defined benefit plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the amendments made by sections 114…
IRCCourt RulingsNov 25, 2002related by meaning
ot entitled to IRA contribution
deductions because they did not substantiate their IRA
deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial
understatement of income tax.
Discussion
In general, the determinations of the Commissioner in a
notice of de…