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89 documents · 0.31sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …on v. Commissioner, T.C. Memo. 2010-140, 99 T.C.M. (CCH) 1576, 1578 ; Schroeder, 78 T.C.M. (CCH) at 568; Murillo , 75 T.C.M. (CCH) at 1566; Pilipski v. Commissioner , T.C. Memo. 1993-461, 66 T.C.M. (CCH) 984, 984. In short, Larotonda was not abrogated by the repeal of section 7 2(m)(4). The funds from petitioner’s T. R…
  2. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024★ strong match
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  4. 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 …
  5. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997
    …stantiation. On his return, petitioner claimed a deduction for gifts to charity in the amount of $2,568, of which $2,132 was listed under contributions by cash or check and $436 was listed under contributions by other than cash or check. To substantiate the deduction, petitioner testified that the claimed contributions…
  6. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  7. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  8. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    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. …
  9. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  10. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  11. 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…
  12. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …k was subject, so that the forfeiture conditions were unlikely to be enforced." Austin, 141 T.C. at 568-569; see sec. 1.83-3(c)(3), Income Tax Regs.2
  13. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …lation did not amount t o an abuse of discretion) , aff’d in part sub nom. Keller v. Commissioner , 568 F.3d 710 (9th Cir. 2009) ; Lindley v. Commissioner , T.C. Memo. 2006-229, 2006 WL 3040938, at *6 ( finding that settlement officer’s errors in calculating reasonable collection potential “were harmless because, even …
  14. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. GEORGE H. ROBINSON, ADMINISTRATOR ANSWERING SERVICE, INC. ESOP
    ERISACourt RulingsFeb 2, 1993
    …al assets of $620,074, total liabilities of $51,957, and net assets available for plan benefits of $568,117. The assets included $484,723 in common stock of the Respondent, $44,734 in "bank investment funds," and $90,281 in "employer's contribution" as "receivables." The principal liability recorded was $51,603, for "s…
  15. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    … No . 1768-07) Accuracy-Related Penalty Year Deficiency Sec . 6662(a ) 2001 $79,946 $15,989 2002 81,568 16,314 2003 72,098 14,420 2004 63,519 12,70 4 Ronald D . Jelling and Lorie A . Jelling (Docket No . 1769-07 ) Accuracy-Related Penalty Year Deficiency Sec . 6662(a ) 2001 $79,946 $15,989 2002 81,568 16,314 2003 71,01…
  16. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    itioner and his wife owned 100 percent of the Garrahan Agency, and since petitioner is a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G). 3. Conclusion The Garrahan Agency is a disqualified person under section 4975(e)(2), and thus it and petitio…
  17. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    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…
  18. 75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 1, 2010
    …um 2 if monthly benefit at URA is— High 3 if monthly benefit at URA is greater than— From— To— 2012 568 568 2,400 2,400 2013 579 579 2,448 2,448 2014 591 591 2,497 2,497 2015 602 602 2,547 2,547 2016 614 614 2,598 2,598 2017 627 627 2,652 2,652 2018 640 640 2,708 2,708 2019 654 654 2,765 2,765 2020 668 668 2,823 2,823 …
  19. DOL EBSA (final agency order) — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. SPALDING AND EVENFLO COMPANIES, INC.
    ERISACourt RulingsNov 18, 1994
    …fter the date the reports were originally due (August 1, 1989). This resulted in the subtraction of 568 days from the 864 day penalty period, resulting in a penalty amount of $44,400 for each plan. He then reduced that amount by 25%, as the DOL had done, resulting in total penalties of $99,900 for the three plans. Spal…
  20. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …sued to the Janangelos for 201 9 determined a deficiency of $6,090 and a section 6663 penalty of $4,568 . Section 6662 penalties were approved in the alternative. Respondent has conceded the section 6663 penalty as to Mrs. Janangelo but maintains that a negligence or substantial understatement penalty is