IRCCourt RulingsJan 2, 2025
… issue s before the Court are whether :
1. petitioners had unreported embezzlement income of $5,307,688
from the transfers that Mr. Hutcheson directed from G Fid and
RSPT and other unreported income of $10,825. We hold they did ;
2. petitioners are liable for a 10% additional tax on an early
distribution from a retirem…
IRCCourt RulingsMar 9, 2011
…ived as part of her retirement, petitioner's investment was
$6,507 and her expected return was $175,688. Thus, section 72(b) authorizes petitioner to exclude 3.7 percent of those payments
received under the city annuity contract which are related to her
retirement.4 As part of her retirement package from-the city,
peti…
IRCCourt RulingsMar 12, 2008★ strong match
…99
-11 -
18 180,699 25,000 155,699 13,456 169,15 5
19 169,155 25,000 144,155 12,532 156,68 8
20 156,688 25,000 131,688 11,535 143,22 3
21 143,223 25,000 118,223 10,458 128,68 0
22 128,680 25,000 103,680 9,294 112,97 5
IRCCourt RulingsJul 8, 1980related by meaning
alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
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
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…
IRCCourt RulingsSep 25, 1996
…y
MPC, with a current unpaid balance of $2,262,253. MIT 84 thus
settled its receivable for MPC for $688,003 less than it was owed. This amount was again termed a "Contract Renegotiation
fee." No formal assignment of the note, however, was ever made.
The Termination Agreement also required MIT 84 to distribute
the Qular…
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…
89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption) ERISAFinal Rules (FR)Apr 3, 2024
…
172,187
$1,729
Notice of Failure to Report Reliance on the QPAM Exemption
17,288 159
Recordkeeping
688,750
688,750
Refusal to Disclose Requested Information
34,577
34,577
QPAMs Losing Eligibility:
Notice to Plans
782
782
Notice to the Department of Prohibited Misconduct and Foreign NPA/DPA
340
340
QPAMs Applying for I…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
the Departments and OPM estimate an annual burden of 8,688 hours, with an equivalent cost of approximately $829,241, to be incurred in 2023 and 2024. The total annual burden for all issuers, FEHB carriers, and TPAs to make the appropriate IT and system changes would be approximately 34,752 hours, at a total cost of ap…
IRCCourt RulingsAug 6, 1997related by meaning
Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous,…
PBGCProposed Rules (FR)Proposed Aug 18, 2023
…368
3,368
2028
816
816
3,445
3,445
2029
834
834
3,524
3,524
2030
854
854
3,605
3,605
2031
873
873
3,688
3,688
2032
893
893
3,773
3,773
2033 or later
914
914
3,860
3,860
1
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 6, 2001
…47, * * * (1963), or the event that “led
to the tax dispute.” Keller St. Dev. Co. v.
Commissioner
, 688 F.2d 681 (9th Cir. 1982). The origin
is determined by analyzing the facts and determining
what the nature of the transaction is. Keller
, 688
F.2d at 681.
Although petitioner in the agreement settling her claim in
th…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…
77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 30, 2012
…From—
To—
2014
599
599
2,531
2,531
2015
611
611
2,582
2,582
2016
623
623
2,633
2,633
2017
636
636
2,688
2,688
2018
649
649
2,745
2,745
2019
663
663
2,803
2,803
2020
677
677
2,861
2,861
2021
691
691
2,922
2,922
2022
706
706
2,983
2,983
2023 or later
720
720
3,046
3,046
1
Table II-A.
2
Table II-B.
3
Table II-C.
( prin…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
IRCCourt RulingsDec 20, 2001
…877 F.2d 624, 631-632 (7th Cir. 1989), affg.
T.C. Memo. 1987-295; Geiger v. Commissioner
, 440 F.2d 688, 689690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner
, 87 T.C. 74, 77 (1986).
34