IRCCourt RulingsAug 8, 2019
…ption of Qualified Trusts) (Westlaw
2019).
- 7 -
distributed to Ms. Soltani-Amadi in 2015 (i.e., $6,686) taxable to her for that year
pursuant to section 72.3 See sec. 402(a).
As a general rule, a distribution from a section 401(k) retirement plan is
fully taxable pursuant to section 72 because the participant's contri…
IRCCourt RulingsJul 14, 2005★ strong match
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…
IRCCourt RulingsApr 16, 2020
…ses listed below that have not been
conceded:
Iten1 Reported Disallowed Conceded At issue
Wages $68,686 $68,686 $65,208 $3,478
Meals and entertainment 2,489 2,489 --- 2,489
Travel 2,456 2,456 --- 2,456
Taxes and licenses 15,317 15,317 15,317 ---
Rent/lease 21,135 21,135 21,135 ---
IRCCourt RulingsApr 26, 2012★ strong match
…for
the determination of a taxpayer's correct tax liability. Petzoldt v. Commissioner,
92 T.C. 661, 686 (1989). If a taxpayer fails to maintain or does not produce
adequate books and records, the Commissioner is authorized to reconstruct the
taxpayer's income. Sec. 446(b); Petzoldt v. Commissioner, 92 T.C. at 686-687.
…
IRCCourt RulingsAug 3, 1979related by meaning
istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsAug 25, 1997★ strong match
there are some matters which require some
testimony.
If that is the case, it's clear that the Court
cannot rule in your favor on the summary judgment motion. You can't get a dispositive answer, which is
what you want. So the next step is trial.
D. Entry of Appearance by Petitioners' Counsel
On July 18, 1994, petitione…
IRCProposed Rules (FR)Proposed Nov 27, 2019
…inted 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
Labor cost
per hour
Total cost
per responden…
IRCCourt RulingsJan 26, 2006
…compensation of $3,557 in tax year 2001. Respondent concedes
that petitioner is not liable for a $1,686 accuracy-related
penalty under sec. 6662(a).
Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a $9,831 deficiency in pe…
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…
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 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…
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…
ERISACourt RulingsAug 31, 2026
…don, 166
F.4th 645, 649 (7th Cir. 2026); accord Meyer v. Duluth Bldg.
Trades Welfare Fund, 299 F.3d 686, 689 (8th Cir. 2002) ;
Penn v. Howe - Baker Engrs., Inc., 898 F.2d 1096, 1100 (5th
Cir. 1990).
III.
Liu argues that the Complaint plausibly alleg es
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…/products/gao-17-259.
Back to Citation
29.
The total number of credit unions is calculated as: 4,686 federally insured credit unions/(100%-2% of credit unions that are privately insured) = 4,782 total credit unions. The number of private credit unions is estimated as: 4,782 total credit unions − 4,686 federally insu…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…products/gao-17-259.
Back to Citation
356. The total number of credit unions is calculated as: 4,686 federally insured credit unions/(100%−2% of credit unions that are privately insured) = 4,782 total credit unions. The number of private credit unions is estimated as: 4,782 total credit unions − 4,686 federally insu…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
IRCCourt RulingsJun 9, 1965
…lroad siding_ 14, 423. 00 4, 200. 74 10, 222. 26
Driveway and parking lot_ 4, 572. 28 1, 885. 97 2, 686. 31
Machinery and equipment_ 468, 797. 15 210, 393. 80 258, 403. 35
Office furniture and fixtures_ 10, 267. 51 3, 327. 46 6, 940. 05
Office machines— 15, 590. 85 8, 989. 54 6, 601. 31
Truck and tractor. 4, 362. 38 3,…
85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 7, 2020
…um 3
if monthly benefit at URA is—
High 4
if monthly
benefit at URA
is greater than—
From—
To—
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
2029
804
804
3,396
3,396
2030
822
822
3,474
3,474
…