IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsMay 29, 1975related by meaning
o was less than the amount claimed by it. Aero’s motion to sever that issue has been granted, and it will be tried subsequently, if necessary.
OPINION The Commissioner has conceded that he bears the burden of proof on the new issues raised in his amended answers. See Rule 142(a), Tax Court Rules of Practice and Procedu…
IRCCourt RulingsMar 14, 2019
…,533 from the California
Public Employees Retirement System (CALPERS), and miscellaneous income of
$737. The IRS determined self-employment tax of $91 and an additional tax of
- 5 -
[*5] $9,153 under section 72(t) (imposing a 10% additional tax on premature
distributions from qualified plans). The IRS allowed petitione…
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 …
IRCCourt RulingsOct 24, 2007
…for
Automatic Extension of Time To File U.S. Individual Income Tax
Return), and a balance due of $3,737 on the line stating “AMOUNT YOU OWE”. The entire $3,737 tax balance reported as owing for
1998 was attributable to self-employment tax on income earned by
Mr. Barrera from his activities as a “business consultant”, w…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
Notice 2005-71 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for October 2005 and the resulti… IRCNoticesOct 31, 2005related by meaning
at time under the laws of that Contracting Party relating to the taxes which are the subject of this Agreement.
Article III
SHIPPING AND AIR TRANSPORT 1. Income derived by an enterprise of a Contracting Party from the international operation of a ship or ships or aircraft shall be exempt from tax by the other Contracti…
IRCCourt RulingsJul 13, 2017
…eived
in 2010 was $20,394, and not $18,657 as reported on the return; thus they failed to
report $1,737 ($20,394 - $18,657 = $1,737) in taxable dividend income.
- 3 -
Background
Some of the facts have been stipulated and are so found. The stipulation of
facts and the accompanying exhibits are incorporated herein by thi…
IRCCourt RulingsApr 26, 1984related by meaning
order (9th Cir., Dec. 22, 1983); Hoover v. Commis sioner, 35 T.C. at 570-571; Duncan v. Commissioner, 30 T.C. 386, 390 (1958).
B. Scandinavian Cruise George spent about 28 hours attending the workshops on the Scandinavian cruise. There seems to be no dispute that these workshops related the corporation’s business. Res…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
re would take a clerical worker, on average, five minutes, resulting in an hour burden of 1,737,781 hours with an equivalent cost of $114,676,201.[82] Table 5—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Burden hours
Eq…
IRCRegulationsSep 9, 2016
…date, is $96,263. The remaining amount due for the 2017 plan year is $125,000 minus $96,263, or $28,737, as of January 1, 2017.(iv) If the final contribution is made on September 15, 2018, the remaining amount due must be increased for interest at the plan's effective interest rate for the 20 1/2 months between January…
80 FR 54374 — Determination of Minimum Required Pension Contributions IRCFinal Rules (FR)Sep 9, 2015
…date, is $96,263. The remaining amount due for the 2017 plan year is $125,000 minus $96,263, or $28,737, as of January 1, 2017.
(iv) If the final contribution is made on September 15, 2018, the remaining amount due must be increased for interest at the plan's effective interest rate for the 20
1/2
months between Januar…
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…
T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont… IRCTreasury DecisionsSep 28, 2015
…date, is $96,263. The remaining amount due for the 2017 plan year is $125,000 minus $96,263, or $28,737, as of January 1, 2017.
(iv) If the final contribution is made on September 15, 2018, the remaining amount due must be increased for interest at the plan’s effective interest rate for the 20% months between January 1…
IRCCourt RulingsNov 23, 2016
…istribution from a qualified retirement plan equal to 10% of the portion of
7Crain v. Commissioner, 737 F.2d 1417, 1417-1418 (5th Cir. 1984).
8Crain v. Commissioner, 737 F.2d at 1417-1418.
- 7 -
[*7] the amount that is includable in gross income. Mr. Blair did not allege that
any of the exceptions under section 72(t) a…
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…l for College Women: Evidence from the Deficit Reduction Act,”
U. Mich. Pop. Studies Ctr.
Report 11-737 (May 2011), available at
https://www.psc.isr.umich.edu/pubs/pdf/rr11-737.pdf
(“[I]ncrease in the price of the Pill on college campuses . . . did not increase the rates of unintended pregnancy or sexually transmitt…
IRCCourt RulingsAug 27, 2018
…ent; to do so might suggest that these arguments have
some colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir.
1984); see, e.g., Cabirac v. Commissioner, 120 T.C. 163 (2003), aff'd without
published opinion, 2004 WL 7318960 (3d Cir. 2004); Rowlee v. Commissioner,
80 T.C. 1111, 1120 (1983) (rejecting …
IRCCourt RulingsJul 22, 1980related by meaning
t acquire a beneficial ownership interest in the ETS trust contributions in 1974.
Because of a concession by respondent with respect to the year 1973, Decision will be entered under Rule 155.
Reviewed by the Court.
Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1954 as amended …
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…l for College Women: Evidence from the Deficit Reduction Act,”
U. Mich. Pop. Studies Ctr.
Report 11-737 (May 2011), available at
https://www.psc.isr.umich.edu/pubs/pdf/rr11-737.pdf
(“[I]ncrease in the price of the Pill on college campuses . . . did not increase the rates of unintended pregnancy or sexually transmitt…
IRCCourt RulingsMay 8, 2017
…nse] as
distinguished from a personal expense"); see also Estate of Yetter v.
Commissioner, 35 T.C. 737 (1961) (finding that funeral expenses were not
properly claimed on estate's fiduciary income tax return but were allowable only