IRCCourt RulingsMar 5, 1987
Fay, Judge:
Respondent determined Federal income tax and excise tax deficiencies as follows:
Petitioners Year in issue Income tax Excise tax deficiency deficiency
Judge and Mrs. Donald J. Porter 1980 $924.00 $90.00
Judge and Mrs. Arlin M. Adams 1980 687.69 76.80
Judge and Mrs. William J. Nealon, Jr. 1981 725.61 90.00
J…
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…
IRCCourt RulingsJul 11, 2024
s income
by $67, 184. Of this amount , $32 , 548 was with respect to petitioners’
SSE Tier 1 and Social Security benefits. The remaining $34 , 636 was with respect to their NSSE Tier 1 , Tier 2 , and supplemental annuity
benefits.
1. Petitioners’ SSE Tier 1 and Social Security Benefits
As to petitioners’ SSE Tier 1 and…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
…080.40 $1,200,202.61 $3,505,101
Travel, training, and supplies $16,182.82 $16,182.82 $16,182.82 $48,548
Overhead (62.92 percent) $715,286.00 $734,956.00 $755,167.00 $2,205,409
The total cost for FYs 2026 through 2028 are therefore projected to be $5,759,058. The number of examination parts provided during FYs 2022, 202…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCCourt RulingsNov 6, 2007
… (Dr . Amarasinghe and his spouse) joint
- 3 -
Federal income tax for 2002, and a deficiency of $36,548 in
136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner IRCCourt RulingsFeb 7, 2011
…ded the net cash surrender value is
greater than zero. --
Schwab's "nò-lapse" premium was set at $3,548.77. This
meant that the policy wouldn't lapse for the first three years--
even if no more premiums were paid--so long as the initial,
premium payment of $136,000 remained greater than $3,548.77 x N
The, parties did n…
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 RulingsFeb 18, 2004
…tioners failed to include on their
original and amended returns the taxable annuity proceeds of $61,548.12 Respondent adhered to the $6,154.94 penalty that
petitioners self-assessed on their amended return for the
$61,549.38 taxable portion of early distributions by Southern
Farm Bureau and Glenbrook.. Respondent inclu…
161 T.C. No. 6 — Estate of James E. Caan, Deceased, Jacaan Administrative Trust, Scott Caan, Trustee, Special
Administrator v. Commissioner IRCCourt RulingsNov 14, 2023
…e
distribution. Held, further, the value of the P&A Interest at the
time of the distribution was $1,548,010.
Held, further, we have jurisdiction under I.R.C.
§ 6213(a) to review R’s denial of D’s I.R.C. § 408(d)(3)(I)
request for a waiver of the 60-day period for rollover
contributions.
Held, further, we review a denia…
IRCCourt RulingsFeb 12, 2014
… policy debt were to equal (or exceed) the cash
value.
- 4 - [*4] Over time Mr. Black borrowed $103,548 against the policy. In addition,
interest due on each loan accrued at a specified annual percentage rate pursuant to
the terms of the policy. Mr. Black did not repay the loans.
In January 2009 the policy was terminat…
IRCCourt RulingsNov 2, 1998
…r an IRA within 60 days of the
- 8 -
6
The record does not explain the discrepancy between the
$405,548.96 and $408,623 amounts.
distribution. Secs. 402(a)(5), 408(d)(3). We note that an IRA
includes only trust s created or organized in the United States.
Sec. 408(a).
On February 27, 1989, petitioner directed that $250…
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 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 RulingsJan 21, 1997
…where appeal lies in this case, focused
precisely on this point in Porter v. Commissioner
, 88 T.C. 548
(1987), revd. 856 F.2d 1205 (8th Cir. 1988), affd. on other
grounds sub nom. Adams v. Commissioner
, 841 F.2d 62 (3d Cir.
1988).
In Porter v. Commissioner
, supra
, we considered whether for
purposes of section 219(g…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…nservation Easement
Donation Allocation
Fee Simple
Donation
Allocation
Piton Group 97% $40,385,950 $548,050
DESE Properties 1.5% 624,525 8,475
1908 Capital PG 1% 416,350 5,650
Dr. Kirkpatrick 0.5% 208,175 2,825
Petitioner did not allocate any of its noncash charitable contributions to
Natural Aggregates, TOFT, Province…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…2,500
Rule Review (In-House)
80,137 = 801,370 Plans × 10% Not Using a Service Provider
4
181.06
320,548
58,038,421
Total
334,756
60,610,921
(2) 2002 Safe Harbor: Notice for New Participants and Beneficiaries
SECURE 2.0 requires that participants and beneficiaries covered under the 2002 safe harbor, who are newly eligib…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…each with specific update and posting requirements. The Departments estimate a one-time burden of 5,548,960 hours for plans (or TPAs on behalf of plans) and issuers, with associated costs of approximately $777,578,040 to add and implement these files, with an ongoing annual burden of 60,040 hours (costing approximately…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …