IRCCourt RulingsFeb 9, 2023★ strong match
…o would be an abuse of its discretion.
See Anderson, Clayton & Co. v. United States , 562 F.2d 972, 980- 981 (5th Cir. 1977)
(“[A] list of some of the considerations that are relevant to a court in reviewing the
Secretary’s exercise of his discretionary power to adopt retroactive regulations * * *
includes: (1) whether…
IRCCourt RulingsOct 18, 2002
… of law. See Higbee v.
Commissioner
, 116 T.C. 438 (2001).
1998
1999
Line 8a. Taxable interest
[1]
$980.00
$1,037.99
Line 9. Ordinary dividends 6,265.99 6,395.04
Line 13. Capital gain or (loss) 14,473.86 19,902.36
Line 15a. Total IRA distributions $85,630.90 ---
Line 15b. Taxable amount 21,407.73
[2]
21,407.50
Line 33.…
IRCCourt RulingsOct 29, 2013
…ement listed the original members of CST to be
First Trust Co. of Onaga FBO Terry Ellis IRA, owning 980,000 membership units
or 98% in exchange for an initial capital contribution of $319,500, and a member
not a party to this action owning the remaining 20,000 membership units or 2%.
Mr. Ellis also requested a Federal …
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 RulingsJun 20, 2001
… and 1995:
1994
1995
Advertising $ 820 $ 720
Car and Truck
expenses
3,879 --
Commissions and
fees
7,980 8,950
Insurance 1,750 1,800
Interest 1,470 1,578
Office expense –- 1,821
Rent 3,350 3,360
Repairs and
maintenance
339 350
Supplies 2,875 2,718
Taxes and licenses 285 245
Utilities 6,487 6,987
Wages 9,500 9,879
- 8 -
…
IRCCourt RulingsMay 11, 1970
…th the following schedule:
Monthly
Basic income pension
0 to $1,579_ $20.
$1,580 to $1,979_ $30.
$1,980 to $2,379_ $40.
$2,380 to $2,779_ $50.
$2,780 to $3,179_ $60.
$3,180 to $3,579_ $70.
$3,580 to $3,979_ $80.
$3,980 to $4,379_ $90.
$4,380 to $4,779_ $100.
$4,780 to $5,179_ $110.
IRCCourt RulingsJul 14, 2005related by meaning
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
ERISACourt RulingsAug 31, 2026
…edent”). Plaintiff contends that before her sister died of
cancer, she elected to receive her $676, 980.77 earned
pension benefits as a lump sum and designated Liu as her
beneficiary. Therefore, Plaintiff argues, she is entitled to the
decedent’s benefits under the Employee Retirement Income
Security Act of 1974 (“ERIS…
IRCCourt RulingsJul 8, 2019
… received it. Accordingly, the
Commissioner determined that petitioner was required to include $524,980 of the
IRA distribution in her 2014 gross income.5 petitioner timely filed a petition with
this Court.
5The record is unclear as to why the Commissioner determined that
petitioner was required to include in gross inc…
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…
IRCCourt RulingsJan 14, 2013
…55
1997 1,169,540 22,903 18,346 41,249
1998 1,238,596 44,632 30,033 74,665
1999 1,265,554 81,916 12,980 94,896
IRCCourt RulingsDec 29, 2005related by meaning
sion plan was formed
before June 25, 1959, because the corpus of that plan has existed
since 1949. Petitioner relies on Rapport de Gestion, UMR, which she states is available on a Web site. We have not considered
that document because it was not offered or admitted into
evidence.
Petitioner contends that we should take…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
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…
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…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
….03 service: 0
Average salary: $30,427.14
( printed page 64232)
Final salary: $45,415.00
Total: $11,980.69; deferred
Total/month: $998.00; deferred
Federal Benefit Payment Computation
Birth date: 11/20/42
Hire date: 06/01/70
Freeze date: 03/08/86
Department service: 15/09/08
Other service:
Sick leave:
.025 service: 15.…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCCourt RulingsSep 25, 2000
…s
the language itself. See Consumer Prod. Safety Commn. v. GTE
Sylvania, Inc.
, 447 U.S. 102, 108 (1980). If the language of the
statute is plain, the function of the court is to enforce the
statute according to its terms. See United States v. Ron Pair
Enters., Inc.
, 489 U.S. 235, 240-241 (1989). All parts of a
statut…
PBGCPBGC Opinion LettersMar 16, 2001
1
Th e M u lti em plo yer Pen si o n Plan Am en d m en ts Ac t o f 1 980 ( “ M PPAA” ) , P. L. 96- 364, 94 Stat . 1 208
( 1 980 ) , am en d ed se c ti o n 4001 ( a) ( 3) o f ERI SA to d ef i n e “ m u lti em ployer plan ” as a pl an
20 0 1-2
§4 0 0 1(a )(3 )
§4 0 0 1(a )( 15)
§ 4005 ( a)
§ 400 5( e)
§ 400 5( f)
§ 4006 …
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…