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…
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…
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…
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 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…
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…
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…
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. …
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…
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…
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 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
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 …
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…
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…
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…
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…
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
…
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…
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