IRCCourt RulingsMar 19, 2009
…rom Ms . Bailey's
section 401(k) plan, and before March 31, 2005, she received a
distribution of $7,527 . .20 from that plan (Ms . Bailey's section
401(k) .plan distribution) .
'Hereinafter, . all section references are to the Internal
Revenue Code (Code) in effect for the year at issue . All Rule
references are to the…
IRCCourt RulingsJun 28, 2010
…ioner's receipt . . and tax
treatment of other payments under the settlement agreement .
incurred $ 527°ofearly withdrawal penalties from two banks .
These penalties were-not reflectedon'petitioner ' s 2005 " return .
IV . The Notice of Deficienc y
In° the notice of 'deficiency issued February 11, 2008,
`respondent adj…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021
…zations electronically. The Form 1120-POL is filed by political organizations, described in section 527 of the Code, to report income not specifically excluded from tax under section 527 and by exempt organizations subject to tax under section 527(f)(1) of the Code. The
( printed page 39921)
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100…
IRCCourt RulingsMar 5, 2018★ strong match
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCProposed Rules (FR)Proposed Nov 27, 2019
timate the total one-time hour burden
( printed page 65509)
would be 2,527,110 hours with an equivalent associated cost of approximately $230,686,747. Table 13A—Estimated One-Time Cost and Hour Burden per Health Insurance Issuer or TPA for the Out-of-Network Allowed Amount File
Occupation
Burden hours
per respondent
La…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…age costs
Total cost
burden
SBC with Coverage Examples to Group Health Plan:
Renewal or Application
527,328 263,664
$105,466
$0
$105,466
Sub-total
527,328
263,664
105,466
0
105,466
SBC with Coverage Examples to Participants and Beneficiaries:
Upon Application or Eligibility
2,030,000
1,015,000
406,000
0
406,000
Upon Re…
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 RulingsMar 13, 1974
…mounts vested and forfeitable were as follows:
Name Vested Forfeitable
Elgin B. Robertson, Jr__ $2, 527. 99 $1, 685. 32
Paul S. Neblett_ 2, 527. 99 1, 685. 32
Chester M. Davis__ 2, 527. 99 1, 685. 33
George B. LaLonde_ 2, 034. 72 1, 356. 48
Max C. Jordan_ 2, 034 72 1, 356. 48
E. L. Snyder_ 2, 034 72 1, 356. 48
W. S. Wa…
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 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 RulingsApr 11, 2012★ strong match
…d the following relevant amounts on its Federal
income tax returns:
2001 2002 2003
Total incomel $2,527,967 $2,316,241 $2,137,828
Less: Total deductions 2,569,771 2,274,031 2,138,283
Taxable income (41,804) (223) (455)
- 7 -
1Gross receipts less cost of goods sold.
2Amount includes deductions for net operatiing loss fr…
IRCCourt RulingsApr 15, 2002
…irs and maintenance 455
Supplies 146
Taxes and licenses 20
Travel 6,768
Meals and entertainment
2
1,527
Utilities 120
Other expenses
3
3,764
Total expenses 13,102
Tentative loss (12,732)
Net loss
4
--
1
All of the reported gross income derived from petitioner’s
handyman activity.
2
Petitioners reported meals and entert…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…
Skidmore deference), affg . 130 T .C . 70 (2008) ; Kornman & Associates, Inc . v . United States , 527 F .3d 443, 454 (5th Cir .
2008) ("Even assuming that revenue rulings satisfy the first
prong of the Mead test, see l .R .C . § 7805(a), they clearly fail
the second .") ; id . ("Furthermore, other circuit courts have…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
IRCCourt RulingsSep 25, 1996
…h method of accounting, MIT 85 claimed a net
loss of $2,700,000, which was the excess of the $3,512,527
payroll costs over reported partnership income of $812,527, an
amount that includes compensation fee income and a relatively
small amount of interest earned.
22
On their individual income tax returns for 1985, the 10…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…
Burden hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Financial Manager
947
$180,527
947
$180,527
Clerical
474
30,044
474
30,044
Total
1,421
210,571
1,421
210,571
Written Authorization From the Authorizing Fiduciary to the Broker-Dealer
Authorizing fiduciaries of new plans and IRAs entering into a re…
IRCCourt RulingsJun 10, 1996related by meaning
mount necessary to fund the
benefits payable under section 415 determined at the time of the
contribution in question. Citrus Valley Estates, Inc. v
. Commissioner
, 99 T.C. at 447. The dispute in these cases focuses
on the amounts of benefits payable under section 415 determined
at the time of the contributions in que…