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…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
t it was final and conclusive and not to be reopened except “upon a showing of fraud or malfeasance or a wilful misrepresentation of a material fact.” In view of the foregoing we conclude that the separate identity of the petitioner and the other two corporations must be recognized in these rebate proceedings. Section …
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013
…ondents each year and that the total annual burden of the collection of information will be about 5,744 hours and $857,195. This represents a burden comparable to that under the existing regulation, as the following table shows:
Annual burden:
Under existing
regulation:
Under proposed rule:
Number of responses
1,026
1,…
IRCCourt RulingsJan 17, 2024★ strong match
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…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023★ strong match
U.S.C. 1108), 112 Stat. 2061; 25 U.S.C. 1647b.
2. Section 890.114 is amended by revising paragraph (a) to read as follows:
§ 890.114
Surprise billing. (a) A carrier must comply with requirements described in 26 CFR 54.9816-3, 54.9816-3T through 54.9816-6T, 54.9816-6A, 54.9816-6, 54.9816-8T, 54.9816-8, 54.9817-1T, 54.98…
IRCRegulationsMay 18, 2016
…etical reserve as of the last day of the 1994 plan year. The theoretical reserve on that day is $14,744—the $13,909 theoretical reserve as of the last day of the 1993 plan year, increased by interest for one year at the rate of six percent. Because the required contribution for the 1993 plan year is taken into account …
IRCCourt RulingsMar 5, 2018related by meaning
e relaxed transfer pricing rules of section 925(a)(1) and (2) were
used instead of the normal section 482 rules, then the lower the profit margin on a particular export transaction, the lower the effective marginal tax rate for that
transaction (because as the profit margin decreased, the amount of taxable income
assig…
IRCCourt RulingsDec 18, 2012related by meaning
taxable income with pinpoint accuracy, the fact of the matter is that
petitioners have no one to blame but themselves. Petitioners, each of whom is a well-educated professional, realized substantial amounts of income during the
subject years and instead of timely reporting that income on Federal income tax
Petitioners…
86 FR 51488 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Sep 15, 2021
…ther for-profit; Not-for-profit institutions.
Forms: Form 5500 and Schedules.
Total Respondents: 24,744.
Total Responses: 24,744.
Frequency of Response: Annually.
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
,180.00
Total: $64,782.34
Total/month: $5,399.00
Maximum: $61,744.00
Maximum/month: $5,145.00
Federal Benefit Payment Computation
Birth date: 06/12/42 Hire date: 03/14/66
Freeze date: 03/30/97
Department service: 31/03/17
Other service:
Sick leave:
.025 service: 20
.03 service: 11.25
Average salary: $75,328.30
Final sa…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…App’x 592 (9th Cir. 2016); Esgar
Corp. v. Commissioner, T.C. Memo. 2012-35, slip op. at 20, aff’d , 744
F.3d 648 (10th Cir. 2014) . If a proposed highest and best use differs
from the current use , it must be reasonably probable and not
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…sh and maintain procedures for the review of each recommendation prior to issuance of an annuity.” [744]
While the 2010 version required that such procedures be “designed to ensure that there is a reasonable basis to determine that a recommendation is suitable,” [745]
the 2020 version requires such procedures be “desig…
IRCCourt RulingsJun 28, 2017
…d medical
expenses that year. Because petitioners' unreimbursed medical expenses did not
exceed $11,744 (7.5% of $156,594)--the floor for an allowable deduction under
section 213--it follows that they are ineligible for the medical expense exception
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…at *41– 42
(quoting Esgar Corp. v. Commissioner, T.C. Memo. 2012-35, 2012 WL
371809, at *8, aff’d , 744 F.3d 648 ( 10th Cir. 2014) ); see also Excelsior
Aggregates, T.C. Memo. 2024-60, at *35.
Both Mr. Ball and Mr. Catlett began their highest and best use
analyses by considering whether the potential use of the Propert…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]