IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
…ar 1
Subsequent years
Burden hours
Equivalent burden cost
Burden hours Equivalent burden cost
Legal
259,230
$42,957,003
259,230
$42,957,003
Total
259,230
42,957,003
259,230
42,957,003
1.3.3.2 Certification by the Senior Executive Officer of the Insurance Company
The Department assumes it will take a Senior Executive Of…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…Citation
756.
This is estimated as: 86,410 Independent Producers × 3 insurance companies covered ≉ 259,230 retrospective reviews.
Back to Citation
757.
This is estimated as: 259,230 retrospective reviews ÷ 358 insurance companies ≉ 725 retrospective reviews, on average.
Back to Citation
758.
This is estimated as: 25…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…ciated with OPM requirements is estimated to be approximately 2,620 hours at an equivalent cost of $259,556 each. The total cost burden associated with OPM requirement is estimated to be $6,801.
( printed page 56073)
Table 20—HHS Summary Cost and Burden of Federal IDR Process for Providers of Air Ambulance Services Sta…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…, by the inflation adjustment factor for 1984 of 2.25867, which resulted in a minimum penalty of $2,259 (rounded to the nearest dollar) and a maximum penalty of $11,293 (rounded to the nearest dollar). The amount of the increase from existing § 702.271(a)(2)'s $1,100 minimum penalty to $2,259 is $1,159, which is less t…
IRCCourt RulingsDec 11, 2003related by meaning
…; Unroe v. Commissioner
, supra
; Counts v. Commissioner
,
supra
.
4
See Williams v. Commissioner
, 114 T.C. 136, 140 (2000).
5
See, e.g., Sloan v. Commissioner
, 102 T.C. 137, 147
(1994) , affd. 53 F.3d 799 (7th Cir. 1995); Hintenberger v.
Commissioner
, T.C. Memo. 1990-36, affd. without published opinion
922 F.2d 848…
IRCCourt RulingsJan 3, 2011related by meaning
gift tax As Mrs. Cadwell
would be the' hypotlietical' donorain' thé scehario posited by
petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention
sec tion 102 (a) , which exc ludes f rom- gros s income the value of
property acquired by Égift Howeve…
IRCCourt RulingsMar 12, 2015
nd.8
SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265
(2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden
of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg
g, Hyd…
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…
80 FR 20158 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Apr 15, 2015
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 259, as set forth below, is added to the table.
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
(pe…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsMar 31, 2015
…herwise have an opportunity to
dispute the liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114 T.C. 604, 609 (2000). The phrase "underlying tax liability" includes the tax deficiency,
additions to tax, and statutory interest. Katz v. Commissioner, 115 T.C. 329, 339
(2000).
In determining whether to sustain the…
IRCCourt RulingsAug 24, 1981related by meaning
in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…n average, five minutes, resulting in an hour burden of 1,737,781 hours with an equivalent cost of $114,676,201.[82] Table 5—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Clerical
1,73…
IRCCourt RulingsJul 20, 2000
…een made under a section 71(b)(2)(A)
divorce or separation instrument. See Bunney v. Commissioner
,
114 T.C. 259, 265 (2000).
The first requirement under section 408(d)(6) is that the
IRA participant transfer his or her interest in the IRA to the
nonparticipant spouse. The parties disagree as to the meaning of
the word…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsNov 21, 2007
…for
1998, 1999, and 2000 are summarized below :
1998 1999 200 0
Income :
1 Gross receipts or sales $114,634
2 Returns and allowances -03 Subtract line 2 from line 1 114,634
4 Cost of goods sold -05 Gross profit, subtract lin e
4 from line 3 114,634
6 Other income -07 Gross income . Add lines 5 and 6 114,63 4
Expenses :…
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. …