IRCCourt RulingsJan 3, 2011related by meaning
…oving party
is -ent itled to judgment as a matter of law. Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965
(7th Cir. 1994) . Facts are viewed in the light most favorable to
the nohmoiring party. Id. However, where a motion for summary
judgment has been properly made and supported, the opposi…
IRCCourt RulingsJan 14, 2013related by meaning
ALS
T.C. Memo. 2013-10
UNITED STATES TAX COURT
THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners
V.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013.
1481-10.
R determined that a corporation's compensation packages for its
owner-employees were unreasonabl…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…mount of retail deposits other than stable retail deposits or brokered deposits, described in § 249.104(c)(1) (row 6); (vii) The average weighted amount and, for each applicable maturity category, the average unweighted amount of sweep deposits, brokered reciprocal deposits, and brokered deposits provided by a retail c…
IRCCourt RulingsApr 22, 2003
ed by PCB that shows Federal
income tax withheld of $2,518. What petitioner did was to claim
a deduction and a withholding credit for the same $2,518. Petitioner properly reported the amount as Federal income tax
withheld. The Court concurs in respondent's determination that
the deduction of the $2,518 as an amount for…
IRCCourt RulingsFeb 9, 2023
of the $5,104,756
trademark royalty payment can be viewed as a $0 adjustment because
respondent agrees with the tax reporting of this amount by the 3M consolidated group. Equivalently, one can think of respondent’s position
on the tax treatment of the $ 5,104,756 trademark royalty payment as
comprising two separate ste…
IRCCourt RulingsMar 9, 2011related by meaning
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…amount of retail deposits other than stable retail deposits or brokered deposits, described in § __.104(c)(1) (row 6); (vii) The weighted amount and, for each applicable maturity category, the unweighted amount of brokered deposits provided by a retail customer or counterparty described in §§ __.104(c)(2), __.104(c)(3)…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…nual cost is estimated as: ($1,340,036 to maintain records + $3,178,800 to distribute records) = $4,518,836.
Back to Citation
536. The first-year total cost includes: ($1,671,795 for rule review + $9,355,525 for general disclosures + $201,597 for policies and procedures + $2,359,860 for the retrospective review + $4,5…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
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…
ERISARegulationsApr 25, 2023
… with respect to the following:
(g)(1) (1) A totally unfunded welfare plan described in 29 CFR 2520.104-44(b)(1)(i);
(g)(2) (2) A welfare plan which meets the requirements of 29 CFR 2520.104-20(b);
(g)(3) (3) An apprenticeship or other training plan which meets the requirements of 29 CFR 2520.104-22;
(g)(4) (4) A pensi…
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 RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…n 100 participants to be small entities.[99] The basis of this definition is found in ERISA section 104(a)(2), which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under ERISA section 104(a)(3), the Secretary may also provide for exemptions or sim…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…enefit plan with fewer than 100 participants.[300] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for pension plans that cover fewer than 100 participants. Under section 104(a)(3), the Secretary may also provide for exempt…
IRCProposed Rules (FR)Proposed May 13, 2026
…r than 100 participants to be small entities.[185] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…