IRCCourt RulingsFeb 9, 2023★ strong match
owing
differences:
I --between the amounts of royalties and other
expenses referred to in article 74 of the
mentioned Law, credited or paid during the base-year, and the minimum percentages
established for the respective deduction,
according to (b) and (d);
II--between the quotas for the purpose of
forming depreciation…
ERISAProposed Rules (FR)Proposed May 8, 2013
ry's benefit statement might look something like this:
Current Balance
Projected Balance
$125,000
$557,534
Monthly Payment
Monthly Payment
$625
$2,788 This shows both total balances (current and projected) and the monthly payments generated by each. The projected balance ($557,534) and related monthly payment ($2,788) …
IRCCourt RulingsMar 31, 2015related by meaning
eir RCP has changed since the time of the settlement
officer's determination because of their middle son's death.
1. Collection Alternatives Generally During the course of a section 6330 hearing taxpayers may propose
collection alternatives such as an OIC or an installment agreement. Sec.
6330(c)(2)(A)(iii); Giamelli v…
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…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…efore taxes
FY ended
taxes of GSI & subsidiaries
GSI & subsidiaries June 30, 1988 $4,302,286 $5,748,557
June 30, 1989 9,725,667 9,759,287
June 30, 1990 11,111,080 11,111,080
June 30, 1991 3,224,665 2,237,628
BI's transition from providing services only to local
merchants, service stations, and banks, to serving some la…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
6.46 6.68
H. Normal cost (beginning of year)
3
7,557,754 8,682,914 9,523,819 11,286,962
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
498,812 896,239 1,225,134 1,454,591
L. Account limit (yearend)
5
8,056,566 14,…
IRCCourt RulingsFeb 28, 2024★ strong match
…of the enacted relief until six years into the future. Cf. Lyons v. United States,
99 Fed. Cl. 552, 557 (2011) (“ The Court believes it would be a great surprise to the Congresses of 1938 and 2004 to discover that the law they
passed . . . might not assist any person who was wrongfully imprisoned
at that time, but poss…
IRCCourt RulingsApr 16, 2020
on payments of $30,557 for 2010, and respondent has conceded that this
amount is not subject to the additional tax. The record contains no evidence of additional qualified education expenses paid for 2010 or any qualified education
expenses paid for 2011.¹5
Accordingly, we find petitioners liable for the 10% additional…
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…1 (defined as the plan year and
limitation year in the ESOP's plan document). Mr. Essy received $41,557 and
$40,000 in wages in the 2000 and 2001 calendar years, respectively. There is no
information regarding the amount Mr. Essy specifically earned during the 12month limitation year from April 1, 2000, to March 31, 20…
IRCCourt RulingsApr 2, 2020
…ne 19.b, and the interest due was shown on line 19.c. For 2003, line 19.a showed the
tax due as $10,557; line 19.b (for penalties) was blank; and line 19.c showed the
interest due "computed to 05/29/2011" as zero (specifically "0.00"). The sum of
all three amounts due was shown as $10,557. For 2004, line 19.a showed th…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
IRCCourt RulingsSep 13, 1990related by meaning
y [section 403(a) of ERTA],
then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent.
[1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsJan 16, 1980
…e deductibility of the contributions is governed by section 404(a)(5). In Educo, Inc. v. Alexander, 557 F.2d 617, 622 (1977), the Seventh Circuit, in reference to plans administered by Educo, stated that such plans “are clearly characterizable as deferred-compensation plans.” The issue before the Court of Appeals in th…
IRCCourt RulingsApr 11, 2012
…ing relevant amounts on its
income tax returns:
2001 2002 2003
Total incomel $719,437 $741,101 $881,557
Less: Total deductions 702,992 ' 741,037 882,456
Net operating loss
19 825 3,380 3,316
carryover >380 (3 316) (4,215)
Taxable income ; ( 3> ) '
IRCCourt RulingsJul 14, 2005related by meaning
0 31
useaee
CAL,
Js.r. Juoca
T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
IRCCourt RulingsMar 9, 2011★ strong match
…ted for those years DISC commissions
of $465,392, $334,315, and $297,052 and taxable income
of $463,557, $333,119,.and $294,657, 'respectively. ADF
deducted the payment of these DISC commissions to ADF
International·.
(2) As a result of its status as a-DISC, ADF
International was deemed to have made distributions of
. …
IRCCourt RulingsMay 11, 2006related by meaning
T. C. Memo. 2006-101 CA
l STA
UNITED STATES TAX COURT . .
EUGENIE DENISE MITCHELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7144-04. Filed May ll, 2006.
Eugenie Denise Mitchell, pro se.
Margaret A. Martin· and Daniel J. Parent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, …
ERISACourt RulingsAug 10, 2026
…o the p lan administrator directly (quoting § 1024(b)(4)) ); Mondry v. Am . Fam . Mut. Ins . Co . , 557 F.3d 781, 796 (7th Cir. 2009) (holding that § 1024(b)(4)
require d the production of a claims administration agreement because , in defin ing the
respective roles of the plan and claims administrators , the agreement…
ERISACourt RulingsAug 10, 2026
…o the p lan administrator directly (quoting § 1024(b)(4)) ); Mondry v. Am . Fam . Mut. Ins . Co . , 557 F.3d 781, 796 (7th Cir. 2009) (holding that § 1024(b)(4)
require d the production of a claims administration agreement because , in defin ing the
respective roles of the plan and claims administrators , the agreement…