IRCCourt RulingsAug 3, 1979related by meaning
155.
Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77.
Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue.
Respondent concedes …
IRCCourt RulingsJan 2, 2020★ strong match
n 72(t) imposes an additional 10% tax on early distributions from a
qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not
attained the age of 59½ when she received the distributions at issue. The IRA
distribution…
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 RulingsJan 31, 1973★ strong match
nforfeitable sick leave the $309,-491 of reserve for nonforfeitable and forfeitable sick leave pay it had deducted at the end of its fiscal year 1965. Eespondent in his notice of deficiency disallowed $309,491 of the deduction claimed by petitioner for sick leave pay for its fiscal year ended March 27, 1965, and increa…
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. …
IRCPrivate Letter RulingsOct 5, 2012
…alities, not legal nicety of title, determine tax
ownership. For example, in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed.
15
It is intended that these investments will at least equal the SIV of all contracts at any point in t ime but they will not match the HAB. Moreover, only
the SMV and SIV, as applica…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…ational laboratories. As explained in section VIII.B of this IFC, we estimate that approximately 83,309 CLIA providers could potentially be performing COVID-19 diagnostic tests and need to publicize their cash prices. For purposes of this IFC, we are estimating it will take a business operations specialist (13-1000), o…
IRCCourt RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…n investigation. HHS seeks comment on these proposed changes.
10. Request for Extension (45 CFR 150.309)
HHS is proposing conforming amendments to revise 45 CFR 150.309 by removing the references to 30 days and clarifying that a responsible entity may request an extension when it cannot prepare a response or provide th…
84 FR 27713 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Jun 14, 2019
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 309 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
( printed page 27714)
Rate set
For plans with a valuation date
Immediate
annuity
rate
(…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
… and
Tomassetti policies were $1 million.
.-473. 2007
On December 27, 2007, Environmental paid $237,309 to Fifth Third Bank
of Florida, as trustee for the benefit of Environmental. The Sterling Plan treated
the $237,309 payment as an employer contribution. On or after May 20, 2008,
Mr. Snyder gave Mr. Tomassetti, on be…
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…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsJun 11, 1996
…yment tenure with the public schools, $2,169.77 in taxable
employer "pick-up contributions",
3
and $309,365.04 of taxable
earnings in the form of interest. The earnings and "pick-up
contributions", which total $311,534.81, constitute the taxable
portion of the Transfer Refund.
Rollover of Petitioner's Transfer Refund
W…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsJul 5, 2005
…) to her IRA. By letter dated January 2, 2001, PERS
notified petitioner that it had transferred $77,309.77 of the
balance to her IRA and had enclosed a “warrant” in the amount of
$4,203.61, which represented her previously taxed contributions.
The letter stated that the total amount of $81,513.38 ($77,309.77
+ $4,203.6…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner IRCCourt RulingsFeb 2, 2022
… of the case
based on public policy or equity considerations.
Murphy v. Commissioner, 125 T.C. 301, 309 (2005), aff’d , 469 F.3d 27
(1st Cir. 2006); see also IRM 5.8.4.2 (May 10, 2013). Compelling public
policy or equity considerations exist when, because of exceptional
circumstances, collection of the full liability w…