IRCCourt RulingsFeb 28, 2024★ strong match
…rohibited from collecting by levy or through a proceeding in court under the provisions of [section 6213(a)] .
4. Coordination of Section 6501 and 6213 Rules
Section 6503, titled “ Suspension of running of period of limitation ,” coordinates the requirements of sections 6501(a) and 6213. Sensibly, the provision extends…
125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner IRCCourt RulingsNov 17, 2005
…ith v.
SSee Estate of Smith v. United States, 300 F. Supp. 2d 474
(S.D. Texas 2004), affd. 391 F.3d 621 (5th Cir. 2004).
- 26 -
United States, 391 F.3d 621 (5th Cir. 2004), affg. 300 F. Supp.
2d 474 (S.D. Tex. 2004). In Estate of Smith, the Court of
Appeals for the Fifth Circuit, affirming the District Court, held
that…
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…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…enalty.” No substantive change results from or is intended by these technical edits.
d. Section 725.621—Reports
Existing § 725.621(a) requires employers to notify the district director upon making a first payment of benefits and upon suspension, reduction, or increase of payments. Existing § 725.621(b) requires employe…
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 …
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019
…, 921, 932, 936; 30 U.S.C. 901
et seq.;42 U.S.C. 405; Secretary's Order 10-2009, 74 FR 58834.
§ 725.621
[Amended]
6. In § 725.621, amend paragraph (d) by removing “January 2, 2018” and adding in its place “January 23, 2019” and by removing “$1,426” and adding in its place “$1,462”.
PART 726—BLACK LUNG BENEFITS; REQUIRE…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…tions for Qualified Plans
618
.02 Definitions for 403(b) Plans
620 .03 Definitions for Orphan Plans
621
.04 Earnings
621
.05 IRA
621
.06 SEP
621
.07 SIMPLE IRA Plan
621
.08 Under Examination
621
SECTION 6. CORRECTION PRINCIPLES AND RULES OF GENERAL APPLICABILITY
.01 Correction principles; rules of general applicability…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
…, 921, 932, 936; 33 U.S.C. 901 et seq.;42 U.S.C. 405; Secretary's Order 10-2009, 74 FR 58834.
§ 725.621
[Amended]
6. In § 725.621, amend paragraph (d) by removing “August 1, 2016” and adding in its place “January 13, 2017” and by removing “$1,375” and adding in its place “$1,397”.
PART 726—BLACK LUNG BENEFITS; REQUIREM…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…and Warren Libutti.
D. Payments and Valuations
1. 2005
On November 25, 2005, Environmental paid $96,621 to Fifth Third Bank of
Florida, as trustee for the benefit of Environmental. On December 9, 2005,
Environmental paid $123,967 to Fifth Third Bank of Florida, as trustee for the
benefit of Environmental. The Sterling …
IRCCourt RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
…, 921, 932, 936; 30 U.S.C. 901
et seq.;42 U.S.C. 405; Secretary's Order 10-2009, 74 FR 58834.
§ 725.621
[Amended]
6. In § 725.621, amend paragraph (d) by removing “January 23, 2019” and adding in its place “January 15, 2020” and by removing “$1,462” and adding in its place “$1,488”.
PART 726—BLACK LUNG BENEFITS; REQUIR…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968
…ted as reported return of advance capital receipt
1960. $99,061.60 $96,673.63 $367,497.72
1961. 356,621.77 348,025.07 863,932.46
1962. 356,621.77 348,025.07 (318,611.88
The facilities exclusively service Pease Air Force Base and had been in continuous use by the Government under the contractual arrangements with petiti…
ERISAProposed Rules (FR)Proposed May 8, 2013
…1(c)(2)(vi), is $557,534. P's December 31, 2012 account balance of $125,000 is projected to be $467,621 assuming a 7% return, compounded annually. Future contributions increasing at 3%, compounded annually with earnings at 7%, compounded annually, are projected to be $524,575 on June 30, 2032. P's aggregate projected a…
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…
IRCCourt RulingsDec 2, 2013related by meaning
T.C. Summary Opinion 2013-96
UNITED STATES TAX COURT
SAMUEL BRACH AND LILLIAN BRACH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15460-12S. Filed December 2, 2013.
Ronald Jay Cohen, for petitioners.
Gennady Zilberman, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was h…
IRCFinal Rules (FR)Oct 8, 2019
…1994, would be expected to sell in March 2019 for $643,750 according to the Case-Shiller Index and $621,448 according to the FHFA Index (see Table 1 below). The agencies also considered housing prices over the most recent financial cycle which were generally at a low point in 2011. During the low point of the cycle, in…
IRCCourt RulingsNov 30, 1981related by meaning
…ners, respondent asserts a deficiency in the full amount of the asserted income tax liability (sec. 6211) and computes the addition to tax under sec. 6653(a) based on that amount (sec. 6653(c)). Respondent implicitly concedes that, for purposes of the sec. 6651(a) addition to tax, petitioners are entitled to take into …
IRCCourt RulingsAug 27, 2026
…mination in violation of the Age Discrimination in Employment
Act of 1967, as amended, 29 U.S.C. §§ 621 – 634 . In August 2021 t he
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…