IRCCourt RulingsFeb 9, 2023★ strong match
t to which the
restrictions apply) has exhausted all remedies
prescribed by foreign law or practice for
obtaining a waiver of such restrictions (other than remedies that would have a negligible
prospect of success if pursued);
(C) The restrictions expressly
prevented the payment or receipt, i n any
form, of part or all…
IRCCourt RulingsSep 9, 1998
T.C. Memo. 1998-321
UNITED STATES TAX COURT
ROBERT J. HOAGLUND, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18418-97. Filed September 9, 1998.
Robert J. Hoaglund, pro se.
Margaret C. Tinagero
, for respondent.
MEMORANDUM OPINION
JACOBS, Judge
: This case is presently before the Court on
respo…
IRCCourt RulingsJul 31, 2000
… before
any experience refund, was $53,150. The policy was credited with
an experience refund of $1,321.18, and the Lakewood Plan paid the
net premium of $51,828.82 ($53,150 - $1,321.18). The cost of
insuring Dr. Hirshkowitz for the third year was $12,095.03, and,
at the end of that year, the conversion credit balance …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…me prescription drugs. As a result, the failure to incorporate these measures reportedly led up to $321.3 million in excess spending during the audit period.[228]
IRCCourt RulingsOct 29, 2013
…A Contribution
Information, for tax year 2005 reflecting a fair market value of the IRA account of
$321,253. This amount consisted of $319,480 of value in the 98% interest in CST
and the remaining cash balance of $1,773."
During tax year 2005 CST paid Mr. Ellis $9,754 as compensation for his
role as general manager 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 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 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…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
s should be ignored and that they should be treated, for the purpose of determining the gross renegotiation rebates, as one corporation, to wit, R. G. LeTourneau, Inc., with three divisions' or plants; and that the single corporation is entitled to include in the single gross renegotiation rebates accelerated amortizat…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…osed 45 CFR 150.313(e).
14. Determining the Amount of Penalty—Aggravating Circumstances (45 CFR 150.321) HHS proposes to amend 45 CFR 150.321 to add a new paragraph (d), which would specify that an entity's failure to cooperate with an investigation or market conduct examination would be considered an aggravating circu…
85 FR 36153 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Jun 15, 2020
…1322, 1322b, 1341(c)(3)(D), and 1344.
( printed page 36154)
2. In appendix B to part 4022, Rate Set 321 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a valuation
date
Immediate
annuity rate
(percent)
Deferred annu…
IRCProposed Rules (FR)Proposed Dec 7, 2018
…Citation
118. HMDA data, December 2015-2017.
Back to Citation
119.
4.5 hours * $71.50 per hour = $321.75. 4.5 hours * $71.50 per hour = $321.75. The FDIC estimates that the average hourly compensation for a loan officer is $71.50 an hour. The hourly compensation estimate is based on published compensation rates for C…
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
.
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
IRCCourt RulingsSep 23, 2019
…utomatically reject the evidence
as unreliable. Lupyan v. Corinthian Colls. Inc., 761 F.3d 314, 320-321, 321 n.2
(3d Cir. 2014). We may discount testimony which we find to be unworthy of
belief, see Tokarski v. Commissioner, 87 T.C. 74, 77 (1986), but we may not
arbitrarily disregard testimony that is competent, releva…
IRCCourt RulingsJul 9, 1997
… 1/15/96 5,564 6,919 1,355
1990 2/26/96 6,709 6,919 210
1990 3/15/96 5,942 6,919 977
1991 5/15/95 2,321 3,039 718
1992 5/16/95 0 2,563 2,563
The parties agree that if respondent prevails on the issues as
stated below, the revised deficiencies and additions to tax will
be as follows:
Year
Statutory
Deficiency
Deficiency…
IRCCourt RulingsFeb 19, 2020
…utomatically reject the
evidence as unreliable. Lupyan v. Corinthian Colls. Inc., 761 F.3d 314, 320-321,
321 n.2 (3d Cir. 2014). We decide whether a witness' testimony is credible by
relying on objective facts, the reasonableness of the testimony, the consistency of
- 16 -
[*16] the witness' statements, and the witness…
IRCCourt RulingsMay 23, 1979related by meaning
ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… broker-dealers affected by this exemption is estimated as: (2,447 retail broker-dealers × 54%) = 1,321 retail broker dealers. The estimated number of non-retail broker-dealers affected by this exemption is estimated as: (1,061 non-retail broker-dealers × 54%) = 573 non-retail broker dealers. The estimated number of to…
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…