IRCCourt RulingsFeb 9, 2023★ strong match
…ations could be modified in any respect .
H.R. Conf. Rept. No. 99-841 (Vol. II), at II- 637 to II - 638 (1986), 1986- 3
C.B. (Vol. 4) 1, 637-638. We have emphasi zed the three sentences of the
conference c ommittee report on which petitioner relies. The first
sentence was quoted by petitioner. The second sentence was c…
IRCCourt RulingsApr 14, 2005
…99 Return, Notice of Deficiency, and Tax Court
Proceedings
On March 10, 2000, petitioner made an $8,638 contribution to her simplified employee pension for 1999. Petitioner calculated
the contribution on the basis of the income she earned under the
personal service contracts.
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Petitioner filed her 1999 Form 1040,…
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 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
IRCCourt RulingsJan 31, 1973
…ployee’s employment. As of March 27, 1965, petitioner set up on its books a further accrual of $127,638, which represented the pro rata part of sick leave of employees from the anniversary date of their employment falling after April 1,1964, to March 27,1965, on the basis of one-half day a month. This accrual represent…
IRCCourt RulingsJul 29, 1997
…. distribution. With respect to the U.S. Trust Co. distribution,
respondent now concedes that only $638 of that distribution is
subject to the additional tax.
Petitioner has made no argument with respect to the section
72(t) additional tax, except by implication of his argument that
the 1992 distribution is not taxable…
Notice 2009-75 — Rollovers from employer plans to Roth IRAs. This notice describes the federal income tax consequences of rolling over an eligible rollover distribution from a … IRCNoticesSep 28, 2009
…llover to a non-Roth IRA followed by a conversion to a Roth IRA. See Notice 2008-30, 2008-12 I.R.B. 638.
IRCCourt RulingsJul 24, 2003
…. With
the two unreported income items conceded by petitioners, their
total income for 1999 was $67,638.
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 …
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
IRCCourt RulingsJun 15, 2009
…cy in tax that the . Commissioner determines . See
Stanley v . Commissioner , `81 , T .C . 634, 637-638,(1983) ; see .
E 1 .6013-4(d), Income Tax Regs .
In order to prove that a taxpayer signed a joint return
under duress, the taxpayer must show (1) that the taxpayer was
unable to resist the demands of the taxpayer's s…
IRCCourt RulingsDec 29, 2005related by meaning
ic employees, (2) the
plan would pay her a taxable annuity after she reaches age 60,
(3) the plan has no survivor benefits, and (4) she would lose all benefits under the plan if she stopped contributing to it.
. The record includes a summary of a tax convention signed by
representatives of France and the United States …
IRCCourt RulingsDec 24, 1985related by meaning
terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange.
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
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…
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 …
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…ubmission contents
637
.05 User fee due at the time of VCP submission using the www.pay.gov website
638
.06 Additional amount due for Group Submissions
638
.07 Additional amounts due for certain submissions
638
.08 Power of attorney requirements
639
.09 Acknowledgement of filing
639
.10 Maintenance of copies of submiss…
IRCCourt RulingsJul 31, 2000
…up term policy was in
its first year.
The second-year premium, before any experience refund, was
$1,638. The policy was credited with an experience refund of
$24.48, and the Lakewood Plan paid the net premium of $1,613.52
($1,638 - $24.48). The cost of insuring Dr. Sobo for the second
year was $370.54.
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Dr. Sobo …
IRCCourt RulingsDec 10, 2012
…n which were forfeited by the time he filed his 1975 income tax return.
In Foulkes v. Commissioner, 638 F.2d 1105 (7th Cir. 1981), rev'g T.C.
Memo. 1978-498, the taxpayer was covered by a pension plan during the taxable
year, but it became clear that he could not acquire any benefit from the plan. Even
though contribut…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsJun 29, 1956
… calendar year 1950 in the amount of $8,468.34. The issue for decision is whether the amount of $27,638.42, received by the petitioner as the designated beneficiary of her deceased father under the rules and procedure of the New York State Employees’ Retirement System and representing the excess of the total amount rec…