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 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…
PBGCRegulationsJan 1, 2017
…ced benefit, determined using the § 4022.23(f) adjustment factor, is $2,785.45 (($350 × 0.387) + $2,650) per month. Since this benefit exceeds the participant's maximum guaranteeable benefit of $1,037.35 per month, the plan administrator must reduce the participant's benefit payment so that it does not exceed the maxim…
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…
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…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…(A × B)
(D)
(E) = (C × D)
First Year
* 68,134,832
100.0
68,134,832
$0.20
$13,626,966
Second Year
32,650,854
100.0
32,650,854
0.20
6,530,171
Third Year
32,650,854
100.0
32,650,854
0.20
6,530,171
Three-Year Average
44,478,847
44,478,847
$8,895,769
Note:
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…
IRCCourt RulingsSep 29, 2016
…led her car.
In order to make her mortgage payments and purchase a new car, petitioner
withdrew $39,650 from her Citibank retirement account in 2012. Petitioner claims
she used the $39,650 distribution as follows: $17,000 to purchase a new car,
$10,000 to pay her mortgage, and the rest to pay other bills.
On her joint …
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…
IRCCourt RulingsApr 25, 2011
ent determined. In the -
alternative, petitioner argues that even if she received $22,650
from OPM in 2005,. she is not liable for any.increase in tax because OPM withheld Federal income tax from her payments. As we
interpret petitioner's argument, petitioner is contending that
OPM withheld insufficient Federal income …
IRCRegulationsMay 18, 2016
… allowance and maximum offset allowance (percent) 70 1.002 69 0.908 68 0.825 67 0.750 66 0.700 65 0.650 64 0.600 63 0.550 62 0.500 61 0.475 60 0.450 59 0.425 58 0.400 57 0.375 56 0.344 55 0.316 Table II[Social security retirement age 66] Age at which benefits commence Annual factor in maximum excess allowance and maxim…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCCourt RulingsFeb 25, 1959related by meaning
ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
IRCCourt RulingsJul 11, 2012
…ersonal property valued at $5,000. Petitioners also reported owning a single
family home valued at $650,000 (subject to one or more mortgages totaling
$889,805), zero equity, and a monthly mortgage payment of $5,862. According to
the Form 433-A, petitioners' home was the subject of a foreclosure proceeding.
Petitioners…
IRCCourt RulingsDec 9, 1971related by meaning
n will be entered under Rule 50.
Drennen, /., dissents.
All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
IRCCourt RulingsDec 29, 2005related by meaning
ic employees, (2) the
plan would pay her a taxable annuity after she reaches age 60,
(3) the plan has no survivor benefits, and (4) she would lose all benefits under the plan if she stopped contributing to it.
. The record includes a summary of a tax convention signed by
representatives of France and the United States …
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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
o the Company or any associated or subsidiary company other than a fortuitous surplus in the event of the dissolution of the Funds or either of them.” On its Federal income tax returns for fiscal 1967 and fiscal 1968, petitioner claimed pension plan contribution deductions in the amounts of $139,446.47 and $89,275, res…
83 FR 9716 — Owner-Participant Changes to Guaranteed Benefits and Asset Allocation PBGCProposed Rules (FR)Proposed Mar 7, 2018
…2(c) is $1,000 per month times 0.65 (the factor from column (b) of Table I in § 4022.62(c)(2)), or $650 per month. Multiplying $650 by the category 4 funding ratio of
2/3
75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections IRCFinal Rules (FR)Jun 28, 2010
…00 people per year.[57]
The elimination of lifetime limits would extend coverage to an estimated 18,650 to 20,400 people who would be expected to exceed a lifetime limit during a calendar year.
Table 3.4—Percent and Number of Persons Expected To Exceed a Lifetime or Annual Limit
Projected to ever exceed limit
Percent…