IRCCourt RulingsJul 5, 2011
… est. Swanson v. Commissioner, T-.C. Memo. 200931 (citing LaVerne v. Commissioner, 94 T.C. 637, 652-653 -(1990),
affd. without pu lished opinion 956 F.2d 274 (9th Cir. 1992));
see Hansen v. Commissioner, 471 F.3d 1021, 1031 (9th Cir. 2006),
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…rial value of assets
VEBA -0- 30,736,554 30,176,217 39,940,676 401(h) -0-
1,125,467
1,172,269
7,598,653
Total -0- 31,862,021 31,348,486 47,539,329
3. Actuarial present value of
future normal costs [1-2]
1
13,361,588 43,354,764 79,243,620 85,002,545
4. Actuarial present value of
future service 4.81 6.63 7.26 7.19
5. Nor…
IRCCourt RulingsJan 3, 2011related by meaning
nclude in gross income
the cash value of a life insurances policy held, by a multiemployer
Unless otherwise indicated, -section refer.ences are to the Internal oRevenue Code o f . 198 6 ( Code ) as amende d and in e f f ec t
for the year sin issue, andrRule- references are t o the Tax Court
Rules of Practicemand Proced…
IRCCourt RulingsJul 31, 2000
…rm policy (certificate No. 6007725) on the life of Dr.
Mall, age 46. The first-year premium was $10,653.50, and the
cost of insuring Dr. Mall for that year was $1,764.60. The
Neonatology Plan paid the first-year premium, and, at the end of
that year, the conversion credit balance was $9,288.90
($10,653.50 - $1,764.60 +…
IRCCourt RulingsJun 17, 1997
…ime Plan
listed the following relevant data:
1988
1989
1990
1991
Fund value at yearend $99,996 $138,653 $158,161 $167,047
Policy values 99,996 138,653 157,814 167,055
Surrender value Unstated Unstated 136,959 147,056
Addit. contr. available (11) 2 61,519 128,443
Date of report 03/11/91 03/11/91 07/10/91 01/20/93
1992
1…
IRCCourt RulingsFeb 22, 1989★ strong match
… board, La.R.S. 42:652 requires that they be credited to the Employees’ Savings Account. La.R.S. 42:653 requires that the employer contributions be credited to the Employer’s Accumulation Account. When the member retires, his or her accumulated contributions are to be credited to the Retiree’s Annuity Reserve pursuant …
IRCCourt RulingsDec 29, 2005★ strong match
…gton University, and Evergreen State
College. In 2001, Central Washington University contributed
$4,653.22 on petitioner's behalf to a. retirement plan in the
IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…stment. See §§ 6234(a) (BBA § 1 101(c)(1), 129 Stat. at 634),
6226(a) (TEFRA § 402(a), 96 Stat . at 653) ; see also Mammoth Cave , 166
T.C ., slip op. at 10. The replacement of the FPAA with the FPA does not
affect the burden of proof. Accordingly, the adjustments in the FPA are
presumed correct , and petitioner bears …
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 …
T.C. Memo. 2017-142 — Block Developers, LLC, William J. Maxam, APC, Tax Matters Partner v. Commissioner IRCCourt RulingsJul 18, 2017
…es:¹4
Additions to tax
Petitioner Excise Tax Sec. 6651(a)(1) Sec. 6651(a)(2)
Mr. Jansson $11,793 $2,653.42 $1,827.91
Mrs. Jansson 11,793 2,653.42 1,827.91
Niklas 11,793 2,653.43 1,827.92
Fred 11,793 2,653.43 1,827.92
We consolidated the cases and tried them in San Diego. Block's principal
place of business was in Calif…
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 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…
IRCCourt RulingsJun 7, 1984
…ry Alice Saunders 1978 1,897.00 304.50
William H. Strong and Ella K. Strong 1978 1979 1980 4,558.31 653.10 653.10 653.10
The issues for decision are as follows:
(1) Whether any portion of the terminating distributions from a pension plan received by petitioner-husbands in 1978 may be "rolled over” tax free to individua…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…n:
A. Legal professional reviews proposed rule (First year)
21,586
0.5
$187.58
$2,024,551
−$6,073,653
21,586
1
187.58
4,049,102
−4,049,102
( printed page 46620)
Primary Assumption
21,586
2
187.58
8,098,204
0
21,586
4
187.58
16,196,408
8,098,204
21,586
5
187.58
20,245,509
12,147,306
2. Notice of Internet Availab…
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…
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…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
…2); Jewell v. United States, 548 F.3d 1168, 1172 (8th Cir. 2008); DeNiro v. United States, 561 F.2d 653 (6th Cir. 1977).