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68 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005
    …stipulated: On May 17, 1998, Petitioner filed a Corporation Application for Tentative Refund ("Form 1139") [petitioner's Form 1139] seeking tentative refunds for the tax years 1994, 1995, and 1996 of $460,999, $473,305, and $286,223, respectively. These tentative refund claims were based on the carryback of a $3,589,78…
  4. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  5. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
  6. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012
    …t some link between petitioner and the Benistar 419 Plan. See Bokum v. Commissioner, 992 F.2d 1136, 1139 (11th Cir. 1993) (distinguishing Scar), aff'a T.C. Memo.
  7. Rev. Proc. 2019-19 — This revenue procedure modifies and supersedes Rev. Proc. 2018-52, 2018-42 I.R.B. 611, the most recent prior consolidated statement of the correction programs …
    IRCRevenue ProceduresSuperseded May 6, 2019
    …to distribute elective deferrals in excess of the § 402(g) limit (in contravention of § 401(a)(30)) 1139 .05 Exclusion of an eligible employee from all contributions or accruals under the plan for one or more plan years 1139 .06 Failure to timely pay the minimum distribution required under § 401(a)(9) 1146 .07 Failure …
  8. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  9. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    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).…
  10. T.C. Summary Opinion 2013-42 — Aster Tirfe v. Commissioner
    IRCCourt RulingsJun 3, 2013related by meaning
    T.C. Summary Jpinion 2013-42 UNITED STATES TAX COURT ASTER TIRF E, Petitioner v. COMMISSIONER OF INTE 1NAL REVENUE, Respondent Docket No. 25865-10S. Filed June 3, 2013. Aster Tirfe, pro se. Steven Roth, for respondent. SUMMARlY OPINION CARLUZZO, Special Trial Judge This case was heard pursuant to the provisions of sect…
  11. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … of a partnership interest in a partnership’s taxable year. Marriott v. Commissioner, 73 T.C. 1129, 1139 (1980). 7 Section 706 specifically applies to variations. § 706(d)(1); Treas. Reg. § 1.706- 4(a)(1). A variation occurs when a p artner’ s interest in a partnership varies during the taxable year as a result of the …
  12. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  13. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  14. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …t estimate of the anticipated experience under the plan. In 1986, Citrus Valley timely filed a Form 1139, Corporation Application for Tentative Refund, and received tentative refunds of income tax for 1982 and 1983 in the amounts of $6,182 and $5,737, respectively. On March 13, 1989, respondent timely mailed Citrus Val…
  15. Treas. Reg. § 1.417(e)-1(f)(2)(ii) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …ction 411(d)(6) for certain plan amendments that incorporate applicable interest rates, see section 1139(d)(2) of the Tax Reform Act of 1986. (f)(3) (3) Other effective dates and transitional rules. (f)(3)(i) (i) Except as otherwise provided, a plan will be treated as satisfying sections 401(a)(11) and 417 for plan yea…
  16. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …ns in mind. See Hellmich v. Hellman , 276 U.S. 233, 237 (1928); H uffman v. Commissioner , 978 F.2d 1139, 1145 (9th Cir. 1992), affg. in part, revg. and remanding in part T.C. Memo. 1991-144. 5. The Statute We begin with the specific language of section 419 A(c)(2), which provides: The account limit for any taxable yea…
  17. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
  18. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012
    … is established in the Commissioner's answer to the petition. See Huffman v. Commissioner, 978 F.2d 1139, 1148 (9th Cir. 1992), aff'g in part, rev'g in part on other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997).
  19. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998
    …Court in Reichenbach v. Commissioner , T.C. Memo. 1995-369, affd. without published opinion 99 F.3d 1139 (6th Cir. 1996). In that case, we found petitioner's "shopworn tax-protester type arguments" to be without merit. in excess of $25,000 whenever it appears that proceedings have been instituted or maintained by the t…
  20. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…