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1. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
   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 — …
2. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003★ strong match
   …ver, to emphasize that our well-established 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). Bas…
3. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
   IRCCourt RulingsMay 3, 1995
   …780 78,030 186,391 Total 420,136 1,155,856 985,541 1,561,521 1,198,532 Net additions (deductions) 1,766,782 264,725 31,990 (1,429,122) 111,600 Beginning year balance -0-1,766,782 2,031,507 2,063,497 634,375 End of year balance 1,766,782 2,031,507 2,063,497 634,375 745,975 At the close of the taxable year ending Decembe…
4. 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…
5. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
   ERISAFinal Rules (FR)Apr 25, 2024
   …ection above, the Department estimates that 1,919 broker-dealers and 2,025 banks will use PTE 75-1.[766] Costs Associated With Disclosure Requirements in Part V
6. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
7. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
   IRCCourt RulingsNov 21, 2007
   … current vested account balance in the ESOP amounted to $467,817 .48 . The statement says that $467,766 .10 of that amount was paid to petitioner in the form of 10,323 shares of J .D . Edwards & Co . stock . The stock was valued as of July 15, 1998, at $45 .31 per share . The statement also says that the payment to pet…
8. 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…
9. PLR 200648028 — Definitions and Special Rules
   IRCPrivate Letter RulingsDec 1, 2006
   …. Rul. 81 - 189, 1981-2 C.B. 240 ( citing Altantic Oil Producing Co. v. United States , 35 F. Supp. 766 (Ct. Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the
10. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …elected had adjusted prices between $3,589 and $3,903 per acre, for an average adjusted price of $3,766 per acre. O n the basis of his analysis, Mr. Ball determined the before value of the Property to be $3,800 per acre, for a value of $1,440,000. We find no flaws in Mr. Ball’s approach, and we find his bottom line to …
11. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
12. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ows: $15,852,213 in 1988, $29,453,541 in 1989, $25,281,057 in 1990, $14,178,375 in 1991, and $7,508,766 in 1992. Prime never valued the Trust as a whole, and Prime never filed a Form 5500 (Annual Return/Report of Employee Benefit Plan)
13. Treas. Reg. § 1.415(b)-1(c)(6) — Limitations for defined benefit plans.
    IRCRegulationsSep 9, 2016
    …2) and (d)(3) for the distribution is equal to $45,954. This amount divided by 1.05 is equal to $43,766. Thus, the annual benefit attributable to the single sum portion of the benefit is $46,912.(v) Conclusion. Q's annual benefit under the optional form of benefit for purposes of section 415(b) is equal to the sum of t…
14. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    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…
15. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …o this shortfall amortization base of $82,005, there is a shortfall amortization installment of $13,766 (which is the amount necessary to amortize the $82,005 shortfall amortization base over 7 years) for each year from 2017 t
16. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
17. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011
    … Drygoods Co..v. United States, 280 U.S. 453, 464 (1930), we used in Beard v. Commissioner, 82 T.C. 766, 777 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986), a fourpart test (Beard test) to determine whether a document submitted
18. 29 C.F.R. § 4022.1 — Purpose and scope.
    PBGCRegulationsJan 1, 2017
    …his part have not been amended to take account of changes made in section 4022 of ERISA by sections 766 and 777 of the Retirement Protection Act of 1994.)
19. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
20. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010★ strong match
    …ayer must execute the return under penalties . of . perjury . Beard v . Commissioner , 82 T .C . . .766, 777 (1984), affd . 793 F .2d 139 (6th Cir . 1986) .- The 2000, 2001, and 2002 Forms 1040 petitioners sent to respondent omitted most of petitioners' taxable income, as discussed above . We conclude that petitioners'…