IRCCourt RulingsAug 26, 1963
OPINION
Raum, Judge:
Petitioner, New York Post Corp., has been a newspaper publisher in New York for many years. It keeps its books and files its income tax returns on an accrual basis of accounting. The question for decision is whether it may deduct on its 1955 and 1956 returns the amounts of $28,987.11 and $33,513.58…
IRCCourt RulingsFeb 9, 2023related by meaning
d
transaction if the taxpayer establishes the following to the
satisfaction of the district director--
(A) Payment or reimbursement for the controlled transaction was prevented at the time of the transaction
because of a foreign legal restriction and circumstances
described in paragraph (f)(2)(ii) of this section; and
…
Notice 2009-8 — This notice provides interim guidance on recently enacted section 457A of the Code which became effective January 1, 2009. Section 457A generally provides that… IRCNoticesJan 26, 2009
ble under § 882 if the compensation had been paid in cash on the date that such compensation ceased to be subject to a substantial risk of forfeiture? A-12 In the case of a foreign corporation with income which is taxable under § 882, § 457A does not apply to compensation that, had such compensation been paid in cash o…
IRCCourt RulingsMar 5, 2018★ strong match
om a related supplier, the FSC is treated no differently for tax purposes
from the way it would be treated if it were a C corporation. See, e.g., sec. 921(d).44 Consequently, contrary to the dissent's suggestion, and far from being a
44For example, if a related supplier had no export income in a particular
year, the FS…
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 RulingsOct 18, 2002
…998
1999
Petitioner Robert L. Helm $2,277 $9,228
Petitioner Sara J. Helm 6,561
6,654
Total 8,838 15,882
C. Petitioners’ Forms 1040
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCCourt RulingsNov 5, 1999
… Inc. v. Commissioner
,
supra
at 886. As in Winger's Depart. Store, Inc. v.
Commissioner
, supra
at 882, a major portion of the assets of
petitioner's pension trust was lent to Morrissey, petitioner's
sole shareholder and trustee of the Defined Benefit Plan. As in
Winger's Dept. Store, Inc. v. Commissioner
, supra
at 8…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…
151.
ERISA section 406, 29 U.S.C. 1106.
Back to Citation
152.
Lockheed Corp.
v.
Spink,
517 U.S. 882 (1996);
Comm'r
v.
Keystone Consol. Indus, Inc.,
508 U.S. 152 (1993).
Back to Citation
153.
Cf.26 U.S.C. 4975(c)(1), Code section 4975(f)(5) defining “correction” with respect to prohibited transactions as placing a…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
d the earlier
of the Participant's life
expectancy * * *.
* * * * * * *
11.2 ALIENATION
(a) Subject to the exceptions provided below, and as otherwise permitted by the Code and Act, no benefit which shall be payable out
of the Trust Fund to any person (including a Participant or the
Participant's Beneficiary) shall be …
IRCCourt RulingsApr 11, 2012
…s:
2001 2002 2003
Total incomel $719,437 $741,101 $881,557
Less: Total deductions 702,992 ' 741,037 882,456
Net operating loss
19 825 3,380 3,316
carryover >380 (3 316) (4,215)
Taxable income ; ( 3> ) '
75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2010
…
2018
640
640
2,708
2,708
2019
654
654
2,765
2,765
2020
668
668
2,823
2,823
2021 or later
682
682
2,882
2,882
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington, DC, this 29th day of November 2010.
Vincent K. Snowbarger,
Deputy Director for Operations, Pension Benefit Guaranty Corporation.
[FR …
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
Notice 2011-3 — Special rules relating to funding relief for single-employer pension plans under PRA 2010. This notice provides guidance on the special rules relating to fundi… IRCNoticesJan 10, 2011
…tallments adjusted to the January 1, 2010 valuation date using the first segment rate of 4.81%, or $882,754 ($1,000,000 - $60,000 - ($60,000 ÷ 1.0481)). The shortfall amortization installment for each of the next 7 plan years (2012 through 2018) is $168,458, determined as the level amount necessary to amortize the rema…
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…
IRCCourt RulingsMar 31, 2008
…1968), affg . T .C . Memo .
- 14 -
1967-102 ; see Livernois Trust v . Commissioner , 433 F .2d 879, 882
(6th Cir . 1970), affg . T .C . Memo . 1969-111 .
Because direct evidence of a taxpayer's state of mind is not
IRCCourt RulingsSep 14, 1993related by meaning
nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if—
(i) such lump sum distribution is received by an ind…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…space.
• Subdivision 12 (May 2014): 4. 25- acre lot consisting of two
contiguous tracts ; sold for $882,000. The parties allocated
$332,00 0 to a 1.57- acre tract with a 0.3-acre (13,068 s f ) building
pad and $550,000 to a 2.68- acre tract with a 0.75- acre ( 32, 670 s f )
building pad. Together these lots sold for $1…
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…