IRCCourt RulingsAug 26, 1963★ strong match
ion plan was finally adopted in 1957, the modest maximum payments of $60 a month were merely supplementary to the retirement benefits involved herein. Notwithstanding that article X of the contract is captioned “Severance Pay,” the fact is that section 4 thereof which is related to the payments here in issue is entitle…
IRCCourt RulingsMar 5, 2018★ strong match
¹² The Commissioner here also doesn't seek to redetermine income tax, but
only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a
distinction from Hellweg to let these cases go forward on the excise-tax issue
alone. Mazzei v…
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…
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 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…
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 …
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 RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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 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…
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…
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 …
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
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…
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…
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…
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
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…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…