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81 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008
    X S R T .C . Memo . 2008-28 8 UNITED STATES TAX COUR T CARL ROBERT WAGENKNECHT , JR ., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 8293-07 . Filed December 22, 2008 . Carl Robert Wagenknecht , Jr ., pro se . Katherine Lee Kosar , for respondent . MEMORANDUM FINDINGS OF FACT AND OPINIO N VAS…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  3. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    on 482 transfer pricing rules that generally apply in allocating income and deductions among related taxpayers. Second, the FSC provisions effectively lowered the tax rate for qualifying export-related taxable income allocated to the FSC. 22See supra note 4. - 30 - A. Relaxed Transfer Pricing Rules Section 925(a) provi…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …lan 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 + $400); the $400 is the interest of 4.5 percent earned on the conversion credit balance (($9,288.90 - $400) x 4.5% = $400)). None of the conversion credit balance could have been transferr…
  6. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    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…
  7. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ption drugs more significantly, consistent with the effect of similar disclosures in other markets.[288]
  8. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
  9. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …al law, but embody state policy.” See Pac . Palisades Bowl Mobile Estates, LLC v. City of L . A . , 288 P.3d 717, 721 (Cal. 2012) (quoting Charles A. Pratt Constr. Co. v. Cal . Coastal Com m’n , 76 Cal. Rptr. 3d 466, 471 ( Ct. App. 2008)). Regardless of whether the primary authority to issue c oastal 13 [* 13] The Cali…
  10. 82 FR 43299 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Sep 15, 2017
    rt 4022, Rate Set 288, as set forth below, is added to the table. 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 annuities (percent) On or after Before i1 i2 i3 n1 n2   *         *         *         *        …
  11. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    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…
  12. 89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption)
    ERISAFinal Rules (FR)Apr 3, 2024
    … on the QPAM Exemption 172,187 $1,729 Notice of Failure to Report Reliance on the QPAM Exemption 17,288 159 Recordkeeping 688,750 688,750 Refusal to Disclose Requested Information 34,577 34,577 QPAMs Losing Eligibility: Notice to Plans 782 782 Notice to the Department of Prohibited Misconduct and Foreign NPA/DPA 340 34…
  13. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
  14. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …State-registered investment advisers × 10% × (100% − 30%)) + (84 insurers × 10% × (100% − 30%)) ≉ 1,288 Financial Institutions updating existing disclosures. The number of financial entities needing to draft their written acknowledgement is estimated as: 200 robo-advisers + 31 non-bank trustees + (1,920 broker-dealers …
  15. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024
    …363 State-registered investment advisers × 10% × (100%−30%)) + (84 insurers × 10% × (100%−30%)) = 1,288 Financial Institutions updating existing disclosures. The number of Financial Institutions needing to draft their written acknowledgement is estimated as: 200 robo-advisers + 31 non-bank trustees + (1,920 broker-deal…
  16. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
  17. 85 FR 81097 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage
    IRCFinal Rules (FR)Dec 15, 2020
    …is approximately $64.52. Thus, the Departments estimate that the overall cost for the estimated 414,288 grandfathered group health plan coverage sponsors and issuers will be $26,729,861.76 ($64.52 * 414,288 total number of estimated grandfathered plan sponsors and issuers).[33] D. Regulatory Alternatives Considered In …
  18. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  19. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986
    …ols v. Coolidge in turn rested for invoking the Fifth Amendment. See, e.g., Porter v. Commissioner, 288 U.S. 436 (1933); Reinecke v. Northern Trust Co., 278 U.S. 339 (1929); Savage v. United States, 331 F.2d 678 (2d Cir. 1964); McIntosh’s Estate v. Commissioner, 248 F.2d 181 (2d Cir. 1957), affg. 25 T.C. 794 (1956); Ba…
  20. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …