IRCCourt RulingsJan 17, 2024★ strong match
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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ated in part, and remanded on another issue sub nom.
JPMorgan Chase & Co. v. Commissioner, 458 F.3d 564 (7th Cir. 2006).
The usefulness of any approach depends on the nature of the property
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…tation
831.
The burden is estimated as: 2,197,679 rollovers × 27.6% involving small entities = 605,564 small rollovers. The labor rate of $64.60 per rollover (based on a rate of $228 per hour for a Personal Financial Adviser) and a material cost of $0.10 per paper rollover disclosure are applied in the following calcu…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…ion of such a test that: (1) Is approved, cleared, or authorized under section 510(k), 513, 515, or 564 of the FD&C Act (21 U.S.C. 360(k), 360c, 360e, 360bbb-3); (2) the developer has requested, or intends to request, emergency use authorization under section 564 of the FD&C Act (21 U.S.C. 360bbb-3), unless and until t…
IRCCourt RulingsDec 11, 2003★ strong match
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsMar 5, 2018related by meaning
ximum of 46% of the combined income to the FSC (by adjusting the sale 1
transfer price). If the profit margin was between 3.98% and 7.96%, the maximum amount of taxable income assignable varied inversely from 46% to 23%,
respectively. If the profit margin exceeded 7.96%, they could assign a maximum
of 23% of the combin…
ERISACourt RulingsAug 14, 2026
…n each class member would be entitled to an individualized award of monetary damages.” Wal - Mart , 564 U.S. at 360–61. This is not to say,
however, that a member in a Rule 23(b)(2) class cannot receive
any monetary relief at all; rather, to the extent that the class
members receive such relief, it must be “incidental …
IRCCourt RulingsJun 18, 1999★ strong match
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCCourt RulingsJan 2, 2008
…l Rule references are to the Tax Court
Rules of Practice and Procedure .
Respondent determined a $6,564 deficiency in petitioner's
2003 Federal income tax and an accuracy-related penalty of $662
pursuant to section 6662(a) .
After concessions,' the issues for decision are : (1) Whether
petitioner is liable for the 10-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…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
or clerical errors); and notice and demand for payment of a jeopardy assessment under section 6861.
(ii)
Tax attributable to TEFRA partnership items. Notice to the partner or the tax matters partner (TMP) of a partnership subject to the unified audit and litigation procedures of subchapter C of chapter 63 of subtitle …
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…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…’ d in part, vacated
in part, and remanded sub nom . JPMorgan Chase & Co. v.
Commissioner, 458 F.3d 564 (7th Cir. 2006).
For vacant, unimproved property, the comparable property sales
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…iciaries:
Upon Application or Eligibility
222,680
111,340
1,855.67
54,928
Upon Renewal
17,129,262
8,564,631
142,743.85
4,225,218
Beneficiaries Living Apart
33,000
33,000
550.00
16,280
Sub-Total
17,384,942
8,708,971
145,150
4,296,426
Uniform Glossary
428,232
428,232
7,137
211,261
Notice of Modification
342,585
171,293
2…
IRCCourt RulingsFeb 28, 2024related by meaning
8
years on June 10, 2016. That notice was issued timely because, as of
3
The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
IRCCourt RulingsAug 27, 2026
…e witnesses, weigh the
evidence, and determine what we believe. Diaz v. Commissioner , 58 T.C.
560, 564 (1972) . Aside from the record ’s patently contradicting many of
Mr. Janangelo’s claims, some of his arguments can only be described as
outlandish, more so in light of his professional background. He persisted
in mak…