IRCProposed Rules (FR)Proposed May 13, 2026
…cting 587.144 (the overall medical care component of the CPI-U (unadjusted) for December 2025) from 625.522 (the overall medical care component of the CPI-U (unadjusted) published by the Department of Labor for December of the previous plan year) and dividing that amount by 587.144 ((625.522-587.144)/587.144). This amo…
IRCCourt RulingsApr 16, 2020
…y for 2013 and 2014.
Withdrawals From Retirement Accounts
In 2010 and 2011 petitioners withdrew $71,625 and $42,858, respectively,
from their retirement accounts. On their 2010 return petitioners reported that they
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[*10] received $50,275 in pension and annuity distributions but asserted the
distributions were no…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…ibution deduction of
$42,200,000 under section 170
1
and determined alternative penalties of
$6,220,625 under section 6662(a), (b)(1)– (3), (c), (d), (e), and (h) and
section 6662A.
After the parties’ filing of Stipulations of Settled Issues,
2
the
issues remaining for consideration are (1) the fair market value of the…
IRCCourt RulingsSep 15, 2005related by meaning
tinued...)
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of the Secretary, and in the same manner as taxes. Sec.
6652(c) (4) (A).
Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to …
IRCCourt RulingsJul 14, 2005related by meaning
that the Court vacate its Order [sic] of
August 16 and order the parties to submit computations
pursuant to Rule 155. This will permit the parties the opportunity to determine whether TLC's liability should
be reduced by the amounts already paid by parties to
the transaction.
On the record before us, we reject petition…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
ERISACourt RulingsJan 20, 1998
…s ."
5CD No. 328 was
outstanding from October 11, 1985 to October 11, 1986 at an
interest rate of 7.625%. CD No. 328 was apparently issued in the
name of "Smith Administrators Medical Claims Account." Ex C16.
As I indicated above, there is no independent evidence
documenting the existence of CD No. 328 or its status as…
IRCCourt RulingsOct 25, 1977
…o:
Date of Repayments of Payments of
repayment principal interest
Dec. 1969.0 $2,656
Dec. 1970.0 10,625
Dec. 28, 1971 .$125,000 10,625
125,000 23,906
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 RulingsFeb 28, 2024related by meaning
stituting a 6-year period in lieu of the 3-year
period otherwise referred to in such subsection.
(D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market
value, subparagraph (A) shall not apply.
Section 313(…
IRCCourt RulingsAug 16, 2005related by meaning
ursuant to section 6015(f) from
liability for the unpaid amount of additional tax liability
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8
SEC. 6015(e). Petition for Review by Tax Court.-- (1) In general.--In the case of an individual
against whom a deficiency has been asserted and who
elects to have subsection (b) or (c) apply–-
(A) In general.--In additi…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…quirements will require 3,066 burden hours that result in $222,224 in estimated labor costs and $19,625 in other costs for printing and mailing. The total estimated updated burden for Federal external review to individual market and non-Federal Government plans is $241,850. This amount includes $222,729 in costs for no…
IRCCourt RulingsMar 3, 1982
n, it would have been necessary for him to withhold a total of $625,000 — $500,000 restricted portion, plus 25 percent thereof as additional security. Consequently, with respect to such $625,000, he would neither be entitled to the special tax benefits applicable to funds held by a qualified retirement plan, nor would …
IRCCourt RulingsMar 20, 1997★ strong match
but did not." Central Tablet Manufacturing
Co. v. United States
, 417 U.S. 673, 690 (1974); Commissioner v.
National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149
(1974). It would be quite intolerable to pyramid the existing
complexities of tax law by a rule that the tax shall be that
resulting from the for…
IRCCourt RulingsNov 4, 1976related by meaning
loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
T.C. Memo. 2014-109 — Leslie J. Molinet Petitioner, and Michael F. Molinet, Intervenor v. Commissioner IRCCourt RulingsJun 9, 2014related by meaning
t available to the
spouse under section 6015(b) or (c). Sec. 6015(f)(1) and (2).
Subsections (b) and (c) of section 6015 apply only in the case of "an understatement of tax" or "any deficiency" in tax, and do not apply in the case of
underpayments of tax reported on joint tax returns. Sec. 6015(b)(1)(B), (c)(1);
Hopkin…
IRCCourt RulingsJul 11, 2024
…that this reference is intended
with respect to Mr. Tuma’s 2015 Form RRB – 1099, which reported
$5, 625 as his SSE Tier 1 benefit amount . This amount of SSE Tier 1
benefit is also consistent with both Mr. Tuma’s 2015 RRB benefit letter
and his 2015 Form RRB – 1099 – R . Mr. Tuma’s 2015 RRB benefit letter
10
R esponden…
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 RulingsJun 29, 2015
…agreements. Pursuant to these agreements the Summa subsidiaries paid JC Export
$129,791, $672,048, $625,438, and $810,646 on January 18, April 23, July 25,
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[*7] and December 22, 2008, respectively.5 Summa also paid $1,083 of expenses
on behalf of JC Export and JC Holding during 2008. The Summa subsidiaries
paid J…
IRCCourt RulingsFeb 2, 2022
…,918. In the notice of deficiency, respondent did not make a separate negative adjustment of $8,680,625 to reverse petitioner’s reported Schedule E passthrough
income from Morley of $8,680,625. Rather, respondent adjusted Mr. Larson’s pro rata
9
[* 9 ] determined that all or part s of Mr. Larson’s underpayments of tax
…