IRCCourt RulingsFeb 9, 2023related by meaning
tax years at issue in L.E. Shunk Latex Products, Inc. v.
Commissioner , 18 T.C. at 955.
As indicated in the table above, tax years 1942 and 1943 (for calendar- year taxpayers) were governed by section 29.45-1 of
Regulations 111, before its amendment by Treasury Decision 5426.
77
As
indicated in the table above, tax ye…
IRCCourt RulingsMar 6, 2001
ciency, id.
, petitioner
cites Chrysler Corp. v. Brown
, 441 U.S. 281 (1979), for the
proposition that respondent’s reopening procedures in Rev. Proc. 94-68, 1994-2 C.B. 803, should have “the force and effect of
law”.
Chrysler Corp. v. Brown
, 441 U.S. at 302 (quoting Morton v.
Ruiz
, 415 U.S. 199, 232, 235, 236 (1974)…
ERISACourt RulingsAug 14, 2026
…“cease, in the ordinary course, upon termination of the bargaining agreement.” Tackett, 584 U.S. at 441–42
(citation omitted); Ro s setto v. Pabst Brewing Co., Inc. , 217 F.3d
539, 543 (7th Cir. 2000) (noting presumption that employee’s
entitlement to retiree healthcare benefits expires with termination of CBA) (citing …
IRCCourt RulingsJan 14, 2013
…9,545 (28,066) 15,636 (12,430)
1991 840,221 3,075 19,586 22,661
-10-
[*10]
1992 894,853 (26,117) 25,441 (676)
1993 957,930 (8,463) 31,601 23,138
1994 982,305 34,585 32,410 66,995
1995 1,066,006 22,767 20,702 43,469
1996 1,127,454 16,063 33,092 49,155
1997 1,169,540 22,903 18,346 41,249
1998 1,238,596 44,632 30,033 74,6…
ERISAProposed Rules (FR)Proposed Jul 21, 2016
…2 regulation disclosure and annual reporting requirements.
U.S. Gov't Accountability Office, GAO-14-441, Private Pensions: Targeted Revisions Could Improve Usefulness of Form 5500 Information
(2014) (available at
www.gao.gov/products/GAO-14-441).
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand 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
.
IRCRegulationsJan 19, 2024
…nterest rate and applicable mortality table under section 417(e)(3), to a straight life annuity of $441.33 per month payable at normal retirement age. Therefore, under the amendment, the portion of Participant R's accrued benefit that is not paid in the form of that temporary annuity must be no less than $1,558.67 per …
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…
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 RulingsMar 7, 2019
…p. 12/30/2000 $17,493 -- $2,015 $2,015 -- -- -- C
Office equip. 12/30/2000 38,560 -- 5,780 4,130 $3,441 $3,441 $3,441 C
Color copier 12/2/2002 1,685 $1,175 163 98 59 59 29 Concedes
Equipment--Krom. 4/15/2003 7,000 7,000 -- -- -- A
Equipment--Henn. 6/18/2003 15,825 15,825 -- -- -- A
4630 Equipment--
IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
… year)
3
8,248,126 9,862,676 12,897,846 13,828,780
I. Benefits paid during year N/A 4,078,160 4,859,441 5,301,930
J. Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
453,647 821,352 958,237 1,335,044
L. Account limit (yearend)
5
8,701,773 15,781,474 25,514,292 36,161,092
M. Actual…
89 FR 3552 — Update to Minimum Present Value Requirements for Defined Benefit Plan Distributions IRCFinal Rules (FR)Jan 19, 2024
…nterest rate and applicable mortality table under section 417(e)(3), to a straight life annuity of $441.33 per month payable at normal retirement age. Therefore, under the amendment, the portion of Participant R's accrued benefit that is not paid in the form of that temporary annuity must be no less than $1,558.67 per …
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 …
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… = $0.76; The mailing rate is applied in the following calculation: (10,000 IRAs × 5.8%) × $0.76 = $441.
Back to Citation
558. This cost is estimated as: ($301,790 to prepare the termination form + $52,875 to distribute the termination form + $441 for material and postage costs) = $355,106.
Back to Citation
559.
The …
IRCCourt RulingsJun 6, 2005related by meaning
a matter of
legislative grace, and the burden of clearly showing the right to
the claimed deduction is on the taxpayer. INDOPCO, Inc. v.
Commissioner , 503 U.S. 79, 84 (1992). We are bound by the
Internal Revenue Code, and it is within the province of the
legislature to decide the circumstances of inclusion, deductions…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…lth plans negotiating contracts annually × $181.06 hourly wage of legal professional × 1 hour = $69,441,580.
Back to Citation
261.
Remy Samuels,
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …