IRCCourt RulingsOct 21, 2003
1
Unless otherwise indicated, section references are to
(continued...)
T.C. Memo. 2003-294
UNITED STATES TAX COURT
RANDOLPH S. SIMPSON, I, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2832-01. Filed October 21, 2003.
Randolph S. Simpson I, pro se.
Gordon P. Sanz
, for respondent.
MEMORANDUM OP…
IRCCourt RulingsNov 26, 2013
dividends of $2,294.88 over the life of the policy. Petitioner did not
recall including the annual dividends in taxable income when they were paid to him, and there is no evidence that NY Life issued any Forms 1099 that would have
prompted him to do so.
In 2009 petitioner surrendered his policy to NY Life, and the com…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCPrivate Letter RulingsDec 1, 2006
…ht. Accordingly, aggregation was appropriate under those circumstances.
Rev. Rul. 79-7, 1979-1 C.B. 294, holds that stock included in the decedent’s gross
estate under the predecessor to section 2035(a) (requiring inclu sion in the gross estate of
IRCCourt RulingsMar 5, 1987★ strong match
…Ill judge does not.
Sec. 371(b) of the Judicial Code. Booth v. United States, supra.
28 U.S.C. sec. 294(b) (1982). Sec. 372(a) of the Judicial Code, unlike sec. 371(b) of the Judicial Code, does not specifically state that the judge retiring under such provision will continue to hold office. However, 28 U.S.C. sec. 294…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
PBGC Op. Ltr. 2001-1 — Becau se the la nguag e of the c ited statu tes is iden tical, thi s letter h ereina fter will PBGCPBGC Opinion LettersFeb 6, 2001
… Int eres t t o 9/15/ 2000
10/15/ 98
[$28,176]
[$32,956]
1/15/ 99
[$62,569]
[$71,692]
4/15/ 99
[$80,294]
[$90,170]
7/15/ 99
[$80,294]
[$88,355]
9/15/ 99
[$76,780]
[$83,325]
10/15/ 99
[$80,294]
[$86,557]
1/15/ 2000
[$80,294]
[$84,795]
4/15/ 2000
[$160,294]
[$165,870]
7/15/ 2000
[$160,294]
[$162,530]
9/15/ 2000
[$319,995…
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…
83 FR 11413 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Mar 15, 2018
Rate Set 294 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set For plans with a valuation date
Immediate
annuity rate
(percent)
Deferred annuities
(percent)
On or after
Before
i1
i2
i3
n1
n2
* * * * …
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMar 13, 2001
…rrespond to the
market value of gold bullion which backed the currency. See
Perry v. United States, 294 U.S. 330 (1935); Nortz v. United
States, 294 U.S. 317 (1935); Norman v. Baltimore & Ohio R.R. Co.,
294 U.S. 240 (1935); Legal Tender Cases, 79 U.S. (12 Wall.) 457
(1870).
As a second ground for rejecting the taxpayer…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…hin the coastal zone are governed by the Coastal Act.
Sierra Club v. Cal. Coastal Comm’n , 111 P.3d 294, 303 (Cal. 2005) (holding that when
a lot straddles the coastal zone boundary, the Coastal Commission retains jurisdiction
over development for the portion of the lot within the coastal zone) . Petitioner provided
no…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsSep 28, 2022
…rain marke ting and storage facility where petitioners stored the crops . CRAT I I distributed $ 69,294
of the proceeds to the charitable remaindermen and used the balance to
purchase a nother SPIA from Symetra . Th is SPIA made annual annuity
payments o f $124, 921 to petitioners in 2016 and 2017. Symetra again
issued…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ntments that would otherwise arise when medication for chronic diseases is not taken as prescribed.[294]
Using data on medical events from the 2022 MEPS, the Department estimates healthcare utilization for privately insured participants aged 18 to 64 with diabetes, hypertension, or heart disease based on adherence stat…
IRCCourt RulingsMar 31, 1961related by meaning
…ence between the tax due and the estimated tax reported and paid. The addition to tax under section 294(d) (2) is properly determined on the basis of 80 percent of tax liability. To correct this error, a Rule 50 computation is necessary.
Reviewed by the Court.
Decision will be entered under Rule 50.
SEC. 72. ANNUITIES:…
IRCCourt RulingsMar 31, 2015
Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the
IRM provision that addresses the Commissioner's ability to levy upon retirement
accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330
hearing request and provided documents supporting this claim. Settlement Officer
Degiovanni …