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83 documents · 0.43sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019★ strong match
    …e Price At trial petitioner husband testified that the cost basis of the Canadian property was $189,946 instead of the $137,493 used by respondent. Petitioners offered into evidence five documents written in French, which they argue substantiate their claim that the cost basis was $189,946. Documents written in a langu…
  2. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    …taxable years ending in 1970 through 1974 was as follows: TYENov.30-Taxable income (loss) 1970 ($16,946.11) 1971 16,113.93 1972 — 13,027.89 1973 _ 8,707.05 1974 3,915.97 On March 16, 1971, the corporation filed with the District Director of Internal Revenue, Buffalo, N.Y., an application for determination (Form 4462) c…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  4. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  5. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …49,681 Enrolled Participants and Beneficiaries 743,361 877,731 First Year Total Costs $1,883,462 $1,946,030 Subsequent Year Total Costs $1,427,080 $1,489,648 L. Alternatives
  6. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  7. 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…
  8. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …assignment or alienation of welfare-plan benefits.26 Davidowitz v. Delta Dental Plan of Cal., Inc., 946 F.2d 1476, 1478 (9th Cir. 1991). And whether such benefits are assignable is left up to the "free negotiations and agreement of the contracting parties.". St. Francis Reg'l Med. Ctr. v. Blue Cross & Blue Shield, 49 F…
  9. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
  10. T.C. Memo. 1998-245 — Richard Raymond Raush v. Commissioner
    IRCCourt RulingsJul 6, 1998★ strong match
    …of September 30, 1994, the account had 15.1473 shares of ESOP stock which were convertible into 302.946 shares of Gillette common stock. On or about December 12, 1994, the plan distributed to petitioner 302 shares of Gillette common stock with a fair market value of $73.19 per share at the time of distribution for a to…
  11. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    …rbara Curcio (Docket 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 81,5…
  12. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  13. T.C. Memo. 2018-49 — Stacey S. Marks v. Commissioner
    IRCCourt RulingsApr 10, 2018related by meaning
    bution out of an IRA that is then paid into another IRA owned by the same owner within 60 days. Id. Under section 408(e)(2)(A), if an IRA engages in a prohibited transaction, the account ceases to be an IRA as of the first day of the taxable year in which the prohibited transaction occurs. - 4 - [*4] Respondent's posit…
  14. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
    IRCCourt RulingsJul 29, 2003
    …ns to Tax Year Deficiency Sec. 6651(a)(1) 1 Sec. 6651(a)(2) Sec. 6654(a) 1996 $62,718 $13,661.55 $3,946.67 $3,164.00
  15. 89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption
    PBGCFinal Rules (FR)Dec 20, 2024
    …864 864 3,648 3,648 2029 884 884 3,732 3,732 2030 904 904 3,818 3,818 2031 925 925 3,906 3,906 2032 946 946 3,996 3,996 2033 968 968 4,088 4,088 2034 990 990 4,182 4,182 2035 or later 1,013 1,013 4,278 4,278 1  Applicable tables for valuation dates before 2025 are available on PBGC's website ( www.pbgc.gov). 2  Table I…
  16. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013
    …uction petitioner claimed for officer compensation related to M. Lipsmeyer for the year 2007 of $62,946; (3) a portion of the deduction
  17. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    te minus amounts received before such date to the extent excludible from gross income. Sec. 72(e)(6). The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to him of income and as the parties have agreed is subject to the 10-percent premature distribution tax und…
  18. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …ondent explained that in the notice of deficiency issued to Mr. Warmoth for 2004 he disallowed $490,946 of the design costs
  19. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    bed in section 72(t) in respect of Mr. Merrell's IRA distribution is sustained. As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case. We have considered similar claims in the past and have observed that there is no -8au…
  20. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
    IRCCourt RulingsSep 2, 2021
    … 58 T.C.M. (CCH) 606, 608 (1989); Isenberg v. Com m issioner, T.C. Mem o. 1987-269, 53 T.C.M. (CCH) 946, 955 (1987); Vandenhoff v. Com m issioner, T.C. Mem o. 1987-116, 53 T.C.M. (CCH) 271, 277 (1987). This industry often requires its participants to m aintain a passion for the work because, without such a passion, a t…