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90 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989★ strong match
    …ll judges in the State. The salary of Louisiana Supreme Court Justices, on an annual basis, was $61,635 from January 1, 1981, through August 31, 1981, and $66,566 from September 1, 1981, through December 31, 1981. Foil’s salary, on an annual basis, was $55,712 from January 1, 1981, through August 31, 1981, and $60,169 …
  2. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    ayer liable for tax if the taxpayer fails to pay the tax within 10 days after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of the right to a hearing before the levy is made. Se…
  3. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …consideration for the 97% interest ; therefore, we do not address this. 17 Petitioner claimed a $41,635,000 deduction for the donation of the conservation easement and a $565,000 deduction for the donation of the fee simple interest, for a total noncash charitable contribution deduction of $42,200,000. 5 Petitioner all…
  4. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    … see generally Hylton v. Commissioner , T.C. Memo. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes
  5. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  6. 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…
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  8. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995★ strong match
    … see generally Hylton v. Commissioner , T.C. Memo. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 1357-1358 (D. Md. 1984); Conway v. United States , 76 AFTR 2d 95-6918 (D. Md. 1995). FINDINGS OF FAC…
  9. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995
    … see generally Hylton v. Commissioner , T.C. Memo. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 1357-1358 (D. Md. 1984). Petitioner Harold L. Humberson (petitioner) was a teacher with the Garrett …
  10. 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
    …ng of submission 633 .07 Compliance statement 634 .08 Effect of compliance statement on examination 635 .09 Special rules relating to Anonymous Submissions 635 .10 Special rules relating to Group Submissions 635 .11 Multiemployer and multiple employer plans 636 SECTION 11. SUBMISSION PROCEDURES FOR VCP .01 General rule…
  11. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    d a refund may be ordered by such court of any amount col lected within the period during which the Secretary is prohibited from collecting by levy or through a proceeding in court under the provisions of [section 6213(a)] . 4. Coordination of Section 6501 and 6213 Rules Section 6503, titled “ Suspension of running of …
  12. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …xpense $2,507.67 5,503.09 2,690.69 2,812.40 Insurance 155.00 155.00 155.00 -0Legal & prof. 432.00 2,635.05 2,635.05 -0Mortg. interest 6,503.89 6,503.89 6,503.89 -0Repairs 4,112.10 5,487.10 5,487.10 -0Taxes 220.00 435.43 435.43 -0Utilities 3,837.35 5,503.09 5,503.09 -0Telephone 587.75 -0- 1,342.33 (1,342.33) Miscellaneo…
  13. PLR 200226001 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsJun 28, 2002
    …those assets may be paid , as a reversion, to the employer. (Emphasis added.) S. Rep. No. 99-313 at 635 (1985) (1986-3 C.B. Vol. 3 at 635) contains the identical provision. H.R. Rep. No. 99-426 at 757 also states Code § 4980 is effective for “ ... a reversion received pursuant to a plan termination occurring after Dece…
  14. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    … The 2023 proposed rules had an error in this calculation resulting in total annual costs of $2,156,635. The correct calculation is as follows: 17,435 disputes × 1.25 hours = 21,794 annual hours and 17,435 disputes × $118.82 per disputes cost = $2,071,583 annual cost. Back to Citation 277.  This was calculated based on…
  15. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  16. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  17. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …oner points out that in Feinberg v. Commissioner, 377 F.2d 21, 24 n.2 (8th Cir. 1967), af[g 45 T.C. 635 (1966), the U.S. Court of Appeals for the Eighth Circuit noted that "[a] taxpayer need not make an affirmative election regarding
  18. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    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…
  19. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …ued liability: Active employees 652,308 1,710,610 2,362,918 CD Retirees 8,892,721 22,637,914 31,530,635 CO 05 00 9,896,844 25,405,545 35,302,389 Petitioner contributed $35,300,000 to the VEBA trust on December 29, 1986. Petitioner claimed a deduction for the full amount of the November and December 1986, contributions …
  20. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996★ strong match
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…