IRCCourt RulingsDec 11, 2003
…tablished precedent enunciated in Beard
v. Commissioner
, 82 T.C. 766, 777 (1984), affd. per curiam 793
F.2d 139 (6th Cir. 1986), resolves this issue.
The Internal Revenue Code does not define the term “return”.
See sec. 6011; Swanson v. Commissioner
, 121 T.C. 111, 122-123
(2003). Based on the Supreme Court’s preceden…
IRCCourt RulingsJul 31, 2000
…the second year was $11,830.58, and, at the end of that year, the
conversion credit balance was $81,793.61 ($39,661.58 + $50,440.40
- $11,830.58 + $3,522.21); the $3,522.21 is the interest of 4.5
percent earned on the conversion credit balance (($81,793.61 -
$3,522.21) x 4.5% = $3,522.21)). Of the conversion credit
bal…
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
…care benefits. The Trustee further
acknowledges that it reported in Form 990-T for 1992 only
$1,155,793 of its investment income for that year as unrelated
business income. Respondent made no determination in the notice
that the Trust’s remaining investment income for 1992 (i.e.,
$405,095), which the Trust did not trea…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…the disclosures would require four pages in total, resulting in a material and postage cost of $158,793.[48]
Table 9—Material and Postage Cost Associated With Sending Disclosures
Year 1
Subsequent years
Activity
Pages
Cost
Pages
Cost
Material Cost
4
$158,793
4
$158,793
Total
4
158,793
4
158,793
1.4 Costs Associated W…
IRCCourt RulingsAug 1, 1996★ strong match
… reduced drastically. In
order to pay off his debts, petitioner made early withdrawals
totaling $24,793.94 from his two retirement plans during 1992.
- 3 -
Specifically, petitioner received a distribution of $14,793.94
from the SEP plan and a distribution of $10,000 from the Keogh
plan. Petitioner received a Form 1099-…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCProposed Rules (FR)Proposed Nov 27, 2019
…of
responses
Burden hours
per respondent
Total burden
hours
Total cost
1,959
23,508
156
305,604
$28,793,069 The Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,527,110 hours and an equivalent associated cost of approximately $230,686,747 to develop and build the Allowe…
IRCCourt RulingsJan 3, 2011
… 2004, petitioner' s policy yas
credited~ eith an" $18 000 premium payment and Nas credÏted with
$2,793 in interest, yielding a total ofs$20,793. ,However,
petitioner'â ]'ife insurance policy incurred a mortality charge of
$8, 496 and other expenses of $2, 640, for, a net value for his 2004
tax yRr of $9 è$7 Indludidg …
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
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 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…
IRCCourt RulingsNov 21, 2007
… to Tax/Penaltie s
Year Deficiency Sec . 6651(a)(1) Sec . 6662(a )
1999 $94,699 .32
$23,674 .83 $12,793 .1 3
2000 1,000 .00 None Non e
Unless stated otherwise, all section references in this opinion
are to the Internal Revenue Code as in effect during the years in
issue .
The issues for decision are
: (1) Whether the d…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
T.C. Memo. 2017-142 — Block Developers, LLC, William J. Maxam, APC, Tax Matters Partner v. Commissioner IRCCourt RulingsJul 18, 2017
…tom lines:¹4
Additions to tax
Petitioner Excise Tax Sec. 6651(a)(1) Sec. 6651(a)(2)
Mr. Jansson $11,793 $2,653.42 $1,827.91
Mrs. Jansson 11,793 2,653.42 1,827.91
Niklas 11,793 2,653.43 1,827.92
Fred 11,793 2,653.43 1,827.92
We consolidated the cases and tried them in San Diego. Block's principal
place of business was i…
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…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026
…R.B. 2026-05 416
Treasury Decisions:—Continued
Article Issue Link Page
10043 2026-15 I.R.B. 2026-15 793
10044 2026-18 I.R.B. 2026-18 840
10045 2026-21 I.R.B. 2026-21 1491
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…
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsAug 16, 2017related by meaning
en of proving that
those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290
U.S. I11, 115 (1933).
I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a
qualified retirement plan equal to 10% of the portion of the amount that is
includable in gros…
IRCCourt RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…