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92 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  2. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    119 1 $63 $43,625,000   Non-Complex Service Providers 9,000 3 119 13 63 10,403,000   Complex Service Providers 1,000 24 119 80 63 7,511,000 2012 Plans 94,000 119 1 63 5,911,000   Non-Complex Service Providers 700 3 119 13 63 867,000   Complex Service Providers 100 24 119 80 63 626,000 Total for 2011 61,539,000 Total fo…
  3. T.C. Memo. 2016-29 — Mark Vandenbosch & Julie Vandenbosch v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    The Vandenbosches rely on Ancira v. Commissioner, 119 T.C. 135 (2002), to show that Dr. Vandenbosch was acting as a conduit or an agent. In Ancira the taxpayer requested the custodian of his self-directed IRA to invest in stock that was not publicly traded but was available directly from the issuer. The custodian drew …
  4. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    an were part of a split-dollar life insurance arrangement. We hold they were; 3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's income in a single, corporate-level proceeding. However, the Small Business Job Protection Act…
  5. 88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCFinal Rules (FR)Dec 21, 2023
    …partments estimate that certified IDR entities collect a certified IDR entity fee for approximately 135,000 disputes annually.[131] Therefore, for the purposes of this analysis, the Departments estimate that certified IDR entities will collect certified IDR entity fees for approximately 94,500 single disputes and 40,50…
  6. 83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Nov 15, 2018
    sacred. 119 Congr. Rec. S5723 In support of the same protections when they were debated in the U.S. House, Representative Margaret Heckler (R-MA) [15] likewise observed that “the right of conscience has long been recognized in the parallel situation in which the individual's right to conscientious objector status in ou…
  7. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  8. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    …% of the basis pool, or $105, was attributable to the remittance. The amount of the remittance was $135 (€100 translated at the spot rate on June 30, year 3, of €1 = $1.35). Therefore, in year 3, DC recognized section 987 gain of $30, equal to the difference between the amount of the remittance ($135) and the portion o…
  9. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …% of the basis pool, or $105, was attributable to the remittance. The amount of the remittance was $135 (€100 translated at the spot rate on June 30, year 3, of €1 = $1.35). Therefore, in year 3, DC recognized section 987 gain of $30, equal to the difference between the amount of the remittance ($135) and the portion o…
  10. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  11. 89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Oct 28, 2024
    …burden (hours) Hourly labor cost of reporting Total cost 45 CFR 47.211 0938-1429 836 836 85 71,060 $119 $8,721,124 26 CFR 54.9815-2715A2 0938-1429 418 418 85 35,530 119 4,360,562 ( printed page 85790) 29 CFR 2590.715-2715A2 0938-1429 418 418 85 35,530 119 4,360,562
  12. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    w why the statute as enacted contains language different from that in the House and - 10 - 1 We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize this Court to grant a declaratory judgment include secs. 6234, 7428, 7477, 7478, and 7479. 2 Sec. 7503 a…
  13. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …89 --- 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 ---
  14. 32 T.C. 759; 10 Oil & Gas Rep. 1162 — Grandview Mines v. Commissioner
    IRCCourt RulingsJun 18, 1959
    … 151.66 298.43 Taxes. 1,074.34 2,140.98 Contributions. 206.00 Depreciation. 73.61 515.70 Depletion. 119,689.38 131,494.22 Other deductions. 5,385.15 11,026.00 Total deductions. (133,370.64) (161,352.83) Net income.-120,210.13 131,494.22 Depletion computation: Total production (sales) 1,714,327.10 1,935,793.57 Share of …
  15. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    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…
  16. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    6,367,005 × 49%) = 3,119,832. Back to Citation 39.  Deloitte, Regulation Best Interest: How Wealth Management Firms are Implementing the Rule Package, (March 6, 2020). This report was released before Regulation Best Interest was effective, so more broker-dealers may now document rollover recommendations. As such, this …
  17. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 2023
    artments assume that certified IDR entities collect a certified IDR entity fee on approximately 135,000 of those 225,000 closed disputes annually.[89] Therefore, for the purposes of this analysis, the Departments estimate that certified IDR entities would collect certified IDR entity fees on approximately 94,500 single…
  18. T.C. Memo. 2016-28 — Raymond S. McGaugh v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    …eld that this principle may apply in the case of a taxpayer and an IRA, see Ancira v. Commissioner, 119 T.C. 135, 138 (2002); and the IRS so acknowledges.5 The question at issue here is whether, in the wire 5As the Commissioner states in his supplemental opposition (at 7-8) to the motion for summary judgment, "if Merri…
  19. 82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Oct 13, 2017
    ed. 119 Congr. Rec. at S5723. In support of the same protections when they were debated in the U.S. House, Representative Margaret Heckler (R-MA) [21] likewise observed that “the right of conscience has long been recognized in the parallel situation in which the individual's right to conscientious objector status in ou…
  20. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    …ual inferences are viewed in a light most favorable to the nonmoving party. Craig v. Commissioner , 119 T.C. 252, 260 (2002); Dahlstrom v. Commissioner , 85 T.C. 812, 821 (1985); Jacklin v. Commissioner , 79 T.C. 340, 344 (1982). The party opposing summary judgment must set forth specific facts which show that a questi…