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86 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  2. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …Hours (1,860 × 519 = 965,340). Total Cost per Respondent × Number of Respondents = Total Cost ($264,840 × 519 = $137,451,960). Back to Citation 51.  Calculation of totals was done as follows: Burden Hours per Respondent × Number of Respondent = Total Burden Hours (9,360 × 205 = 1,918,800). Total Cost per Respondent × N…
  3. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    suers and FEHB carriers, the total first-year burden is estimated to be 4,857,840 hours with an equivalent total cost of approximately $662,015,640.48 TABLE 6: Estimated Total First-Year Cost and Hour Burden for Issuers and FEHB Carriers to Design, Develop and Implement Needed IT System Changes and Submit Required Data…
  4. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …ustomize it 4,076 10 6 244,560 167.48 40,958,909 Plan MEWAs that are not fully insured 132 10 12 15,840 167.48 2,652,883 Non-plan MEWAs that are not fully insured 21 10 12 2,520 167.48 422,050 Subsequent Years Total 5,041 360,360 60,353,093 Total (3-year average) 5,041 840,840 140,823,883
  5. T.C. Memo. 1996-240 — Richard L. & Betty L. Seltzer v. Commissioner
    IRCCourt RulingsMay 23, 1996
    …rmy 13,939.68 14,736.99 15,581.40 OPM 11,447.84 13,680.00 14,412.00 Total $29,036.84 $32,165.31 $33,840.72 During the year 1989, after having his annuity distributions reduced as discussed above, petitioner received annuity benefits from OPM in the amount of $11,447.84. 4 Although the Form W-2P(A) issued by OPM to peti…
  6. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
  7. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …ealing by unjustified hindrance" of contract performance); In re Econ. Lodging Sys., Inc., 226 B.R. 840, 844 (Bankr. N.D. Ohio 1998) (stating that a breach of contract may occur where "one party to a contract wrongfully prevents the other party's performance"), aM, 234 B.R. 691 (B.A.P. 6th Cir. 1999); Barrett v. Gilber…
  8. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …ng pad to the average building pad size of 43, 996 square feet yields an indicated value of $ 1,759,840 per lot . ii) Price p er Lot Mr. Williams and Mr. DuVall estimated the value of the northern
  9. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
  10. 88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCFinal Rules (FR)Dec 21, 2023
    e, for approximately 108,000 single determinations and 24,840 batched determinations (not subject to the batched percentage fee amount) annually,[134] if current certified IDR entity fixed fees remained applicable, the Departments estimate that the parties would pay approximately $59,292,000 for single determinations (…
  11. 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…
  12. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
  13. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …1 MIT 83 1986 519,960 3453-92 MIT 85 1986 412,722 1987 1,865,187 1988 1,419,986 3456-92 MIT 82 1987 840,069 1988 275,156 1989 1,274,633 3457-92 MIT 80 1986 443,415 - 7 - 1987 840,838 1988 969,316 1989 1,335,995 3461-92 MIT 84 1986 546,300 1987 1,315,352 1988 23,889 1989 1,423,786 3462-92 MIT 86 1987 4,855,505 3551-92 M…
  14. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  15. 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…
  16. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  17. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    … AP Transfers 337,484 337,484 337,484 337,484 337,484 337,484 337,484 337,484 337,484 337,484 3,374,840 Post-Rule (RCH/PSN Grows, $7,000 Distribution Limit) Coverage/Match Factor 65% 72% 78% 82% 84% 86% 88% 89% 90% 90% Default IRAs 954,786 976,384 994,897 1,007,239 1,013,410 1,019,581 1,025,752 1,028,837 1,031,923 1,03…
  18. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  19. 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…
  20. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …sputes withdrawn—95 percent (15,960) disputes withdrawn against the top 10 non-initiating parties = 840 disputes withdrawn against other non-initiating parties. 840 disputes/1,695 issuers/TPAs = less than 1 dispute withdrawn per issuer/TPA annually. 1 dispute × $9.89 per dispute = $10 per small issuer/TPA. Back to Cita…