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Go to 15 T.C. 947 (not yet in the library — opens the official source)
91 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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 …
  2. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026★ strong match
    …f law.’” Whistleblower 14376-16W , T.C. Memo. 2024- 22, at *31 n.21 (quoting Marks v. Commissioner, 947 F.2d 983, 986 n.1 (D.C. Cir.
  3. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …3,361,586 $38,521,857 $62,860,146 $83,594,015 Retired employees 26,311,902 36,694,928 47,731,960 48,947,859 Total 39,673,488 75,216,785 110,592,106 132,541,874 2. Actuarial value of assets VEBA -0- 30,736,554 30,176,217 39,940,676
  4. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …-insurance aircraft 15,000 15,000 other deductions--aircraft fees 429 429 Other deductions--pilot 3,947 3,947 Management fees 4,800,000 4,595,000 Balance sheet--forgone interest 69,256 117,356 Cost of goods sold--ending inventory 220,950 785,056 Total adjustments 5,265,041 5,672,217 - 37 - OPINION I. Burden of Proof in…
  5. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …any were arm’s-length rates because they were the same rates charged to unrelated customers. Id. at 947. The government had contended that the unrelated- party transactions were infrequent, low -v olume transactions that were not comparable to the transactions between the Liberian company and the U.S. company. Id. at 9…
  6. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  7. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  8. 88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCFinal Rules (FR)Dec 21, 2023
    …20, and that the typical batched determination fixed fee (range $268-$1,173) will be approximately $947. At an estimated cost of $520 per single determination for approximately 94,500 single determinations annually, the Departments estimate that single determinations will cost disputing parties approximately $49,140,00…
  9. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026
    …87.50 $2,243 Premiums 2,259 1,858 243,880.99 499.80 4010 Information 448 * 28 0 0 Reportable Events 947 0 0 0 * There were an additional 197 waivers issued under the one-time 4010 filing waiver in PBGC's Technical Update 23-1 (August 7, 2023).
  10. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    an excise tax (sec. 4980 of the Code)." (Emphasis added.) Certainly, it would seem highly unlikely that Congress could have intended a mere 10 percent excise tax to replace the tax on income at a substantially higher rate, and there is nothing in the legislative history relating to the increase in the excise rate from …
  11. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 2023
    …0, and that the average batched determination fixed fee (range $268-$1,173) would be approximately $947. At an estimated cost of $520 per single determination for approximately 94,500 single determinations annually, the Departments estimate that single determinations would cost disputing parties approximately $49,140,0…
  12. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  13. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  14. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …765 Gross income from property: Feldspar at $13__ $340, 808. 00 $340, 808. 00 _ Sand at $4.99_ 437, 947. 35 _ $437, 947. 35 Byproduct sales_ 1, 345. 05 309. 36 1, 035. 69 Total_ 780,100. 40 341, 117. 36 438, 983. 04 Less royalties_ 22, 895. 89 5, 266. 05 17, 629. 84 Gross income — adjusted_ 757, 204. 51 335, 851. 31 42…
  15. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    … Activity Burden hours Equivalent burden cost Burden hours Equivalent burden cost Financial Manager 947 $180,527 947 $180,527 Clerical 474 30,044 474 30,044 Total 1,421 210,571 1,421 210,571 Written Authorization From the Authorizing Fiduciary to the Broker-Dealer Authorizing fiduciaries of new plans and IRAs entering …
  16. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …D Fair Labor Standards Act Child Labor that causes serious injury or death 29 CFR 570.140(b)(2) $56,947 $58,383. WHD Fair Labor Standards Act Child Labor that causes serious injury or death 29 CFR 579.1(a)(1)(i)(B) $56,947 $58,383. WHD Fair Labor Standards Act Child Labor willful or repeated that causes serious injury …
  17. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …8 6,431,204.00 3,386,861 1974 71,160,232 8,054,746.00 4,105,409 1975 97,583,835 12,739,821.00 6,858,947 1976 141,912,127 23,418,981.00 12,175,105 1977 168,944,103 27,330,113.00 14,416,901
  18. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4,789,467 30,420,770 B. Suspense Account transactions
  19. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  20. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…