IRCCourt RulingsSep 26, 1968
Simpson, Judge:
The respondent determined deficiencies in the income tax of the petitioners of $1,523.06 for the taxable year 1961 and $5,045.75 for the taxable year 1962. The only issue remaining for decision is whether a distribution received by the petitioner Maurice Osterman in 1962 from an exempt employees’ pensio…
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…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
.1763434
4,826,970
$504,465,709
$784,429
2023
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
735,318
2024
4,059,610
4,103,368
1.1763434
4,826,970 504,465,709
735,318
3 Year Average
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
751,688
Table 52—DOL's and Department of the Treasury's Summary Table
Year
Estimat…
IRCCourt RulingsMar 16, 2006
…isability, entitling her to disability annuity
payments as of July 1, 1998.
Petitioner received $14,970.84 in annuity payments from the
RRB during the 2001 taxable year. For that year, petitioner
-3received a Form RRB-1099-R, Annuities or Pensions by the Railroad
Retirement Board. Listed on the Form RRB-1099-R are the
…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsMar 31, 2005
…r failed to report the $11,567
distribution from Standard Insurance Company, and the additional $46,970 distribution from New York Life from Mr. Seidel’s CWSC
- 9 -
3
The amount of $5,442 which was disallowed by respondent is
actually the total net loss reported on Schedule C from
petitioner’s activity, Port of Mystery…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
ment provides A with notice of the specific amount of the liability and the basis for that liability as described in this paragraph (a)(7).
Example 2. Taxpayer B is a partner in partnership P, a TEFRA partnership for taxable year 2005. B claims a distributive share of partnership income on B's Federal income tax return…
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 …
IRCCourt RulingsApr 19, 2005
… deficiency mailed to Ms. Seidel respondent determined that she failed to
report the additional $46,970 distribution from New York Life
from petitioner’s CWSC 401(k) plan.
- 8 -
Although Ms. Seidel reported one-half of the net
distribution of $60,060, or $30,030 in gross income on her 1999
Federal income tax return, sh…
IRCCourt RulingsJan 5, 2017★ strong match
n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20%
5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference
to any SFRs. Even if it did, the literal transcript does not establish that the
requ…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…den hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Financial Adviser
622,676
$141,970,058
622,676
$141,970,058
Total
622,676
141,970,058
622,676
141,970,058
These rollover disclosures
are expected to be two pages in length and accompany other documentation associated with the transactions at no additi…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
IRCCourt RulingsJan 14, 2013★ strong match
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…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…ofit institutions.
Respondents:
2,588,983.
Responses:
33,829,725.
Estimated Total Burden Hours:
303,970.
Estimated Total Costs:
$15,224,218.
Description:
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…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023
…ceipt of such cash under section 6050I and these regulations.
(ii)
Casinos exempt under 31 CFR 1010.970(c).
Under the authority of section 6050I(c)(1)(A), the Secretary may exempt from the reporting requirements of section 6050I casinos with gross annual gaming revenue in excess of $1,000,000 that are exempt under 31 C…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
ERISACourt RulingsAug 25, 1995
…es. John Hancock Mutual
Life Ins. Co. v. Harris Trust and Savings Bank, 14 S.Ct. 517
(1993), citing 970 F.2d 1138 at 1145.
In Hancock there was an existing defined ERISA plan.
At issue was whether certain assets were "plan assets" with
respect to general fiduciary responsibilities. In
Hancock, the Court held that a gro…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021
…ceipt of such cash under section 6050I and these regulations.
(ii) Casinos exempt under 31 CFR 1010.970(c). Under the authority of section 6050I(c)(1)(A), the Secretary may exempt from the reporting requirements of section 6050I casinos with gross annual gaming revenue in excess of $1,000,000 that are exempt under 31 C…
IRCCourt RulingsJun 25, 1981
…n exchange for a stated consideration in money or money’s worth.” Freeland v. Commissioner, 74 T.C. 970, 980 (1980). Also, in focusing on the rights petitioner relinquished (to share in the management and control, the income from, and the proceeds of disposition) we note that the courts have tended to reject technicali…