IRCCourt RulingsJan 14, 2013★ strong match
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…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
10,592,106 132,541,874
C. Value of assets (beginning of year)
a. VEBA --- 30,736,554 30,176,217 39,940,676
b. 401(h) --- 1,125,467
1,172,269
7,598,653 c. Total --- 31,862,021 31,348,486 47,539,329
D. Nondeductible contribution from prior
years (O from prior year) --- 22,034,781 14,394,743 14,426,384
E. Net value of ass…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsFeb 24, 2014
115 Stat. at 97, amended sec. 415(c)(1)(A) by increasing the dollar limit
from $30,000 to $40,000. EGTRRA sec. 611(b) is effective for years beginning after December 31, 2001. EGTRRA sec. 611(i), 115 Stat. at 100.
EGTRRA sec. 632(a)(1), 115 Stat. at 113, amended sec. 415(c)(1)(B) by
increasing the percentage limit from…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJan 21, 2020
(2002); FPL Grp., Inc. & Subs. v. Commissioner, 115 T.C. 554, 559
(2000).
Petitioner failed to respond to respondent's motion as ordered by this Court and has failed to demonstrate that there is a genuine dispute for trial.
Consequently, we conclude that there is no dispute as to any material fact and that
a decision m…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… transfer ($18,795) by the total annual downloads (1,200): $18,795 × 1,200 downloads per year = $22,554,000.
Back to Citation
218.
Total network cost savings are calculated by subtracting the total annual network costs for the new files downloaded quarterly ($22,554,000) from the total annual costs for the current mon…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…nd (e), 3121(b)(8)(A), and 3401(a)(9).)
(24) Section 111.—See section 3.01(13), above.
(25) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s compensation claims is excluded from gro…
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 RulingsJul 31, 2000
…1992
(As amended)
Total income $2,303,425 $403,869 $2,411,265 $2,286,460
Officers’ compensation 987,554 350,000 1,171,931 940,895
Salaries & wages 148,750 29,167 200,565 303,750
Pension, profit-sharing, plans 46,907 25,000 132,428 169,170
Employee benefit programs -0- -0- -0- -0-
Other deductions (VEBA contribution) 48…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
…rs the following amounts for
renewal premiums:
Date
Premiums
9/6/83 $549,699
7/23/84 556,843
9/6/85 554,390
8/26/86 554,390
8/28/87 530,650
8/31/88 526,325
6. Commissions Paid by Travelers to the Garrahan Agency
During the years at issue, the Garrahan Agency received the
following amounts as commissions from Travelers …
85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 7, 2020
…
2028
786
786
3,319
3,319
2029
804
804
3,396
3,396
2030
822
822
3,474
3,474
2031 or later
841
841
3,554
3,554
1
Applicable tables for valuation dates before 2021 are available on PBGC's website (
www.pbgc.gov).
2
Table II-A.
3
Table II-B.
4
Table II-C.
* * * * *
Issued in Washington, DC.
Hilary Duke,
Assistant Gene…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsOct 10, 1979
…erest element in mind. See, e.g., H. Rept. 704, 73d Cong., 2d Sess. 21 (1934), 1939-1 C.B. (Part 2) 554; S. Rept. 558, 73d Cong., 2d Sess. 23 (1934), 1939-1 C.B. (Part 2) 586. Admittedly, an interest factor is usually present where an annuity is involved. See Hill’s Estate v. Maloney, 58 F. Supp. 164 (D. N.J. 1944); La…
IRCCourt RulingsFeb 18, 1998related by meaning
lure to report any portion of
the distributions. Thus, we find petitioner liable for the
negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock.
In keeping with the above holdings,
Decision will be entered
under Rule 155
.
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsJan 27, 2005
…plans.
On their joint Federal income tax return for 2000,
petitioners reported as gross income the $115,142.97 in distributions from their qualified plans. Petitioners included
with their 2000 tax return Form 5329, Additional Taxes
Attributable to IRAs, Other Qualified Retirement Plans,
Annuities, Modified Endowment Co…
IRCRegulationsJul 26, 2016
…2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Survivor Annuities; Two Lives—Expected Return Multiples Ages 105 106 107 108 109 110 111 112 113 114 115 105 2.5 2.4 2.3 2.2 2.1 2.0 2.0 1…
82 FR 29236 — Definition of Employee Pension Benefit Plan Under ERISA ERISAFinal Rules (FR)Jun 28, 2017
… Rec. p. S2692-2712.) President Trump signed the resolution into law on May 17, 2017, as Public Law 115-35. Also on February 15, 2017, the United States House of Representatives, under authority of the Congressional Review Act, passed joint resolution H.J. Res. 67 disapproving the December 20, 2016, final rule publishe…