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83 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …thetical buyer would take it into account. See Estate of Smith v. United - 15 - States, 391 F.3d at 628.6 Because the tax burden associated with distributing the assets in the IRAs will never be transferred to a hypothetical buyer, we find that the reasoning of Estate of Davis v. Commissioner, supra, inapplicable to th…
  2. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …e labor rate is applied in the following calculation: 1,749,471 claims × 0.50 hours × $101.32 = $88,628,201. Back to Citation 285.  The burden is estimated as follows: 1,749,471 uninsured individuals in need of good faith estimates with additional items and services × 0.50 hours = 874,736 hours. A labor rate of $101.32…
  3. Treas. Reg. § 1.417(a)(3)-1(e) — Required explanation of qualified joint and survivor annuity and qualified preretirement survivor annuity.
    IRCRegulationsSep 9, 2016
    …ments under the QJSA are 87.62 percent of the monthly payments under the single life annuity, or $2,628.60 per month, and provides this information to M.
  4. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …ss income for the subject years includes nonemployee compensation of $483,591, $487,873, $536,145, $628,500, $694,986, and $815,963, respectively, that Ms. Zaklama realized from her selfemployment, and whether petitioners may deduct self-employment business 4We decide these issues bearing in mind that issues and argume…
  5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    … and, at the end of that year, the conversion credit balance was $14,599.19 ($17,390 - $3,419.48 + $628.67); the $628.67 is the interest of 4.5 percent earned on the conversion credit balance (($14,599.19 - $628.67) x 4.5% = $628.67)). None of the conversion credit - 37 - balance could have been transferred at this tim…
  6. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …rt Larsen v. Commissioner, 89 T.C. 1229 (1987), and aff'g Casebeer v. Commissioner, T.C. Memo. 1987-628, Moore v. Commissioner, T.C. Memo. 1987-626, and Sturm v. Commissioner, T.C. Memo. 1987-625. See Sacks v. Commissioner, 69 F.3d at 988 ("Our analytic task is to decide whether Mr. Sacks'
  7. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    …pants: Mortgages -0- -0Other 152,112 -0- Total investments 152,112 137,270 Total assets 191,680 179,628 Liabilities Total liabilities -0- -0- Net assets 191,680 179,628 The Form 5500 also reports expenses of $20,653 which represented distribution of benefits directly to participants. The Schedule B for the year ended O…
  8. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  9. PLR 201434030 — Substantially Equal Payments
    IRCPrivate Letter RulingsAug 22, 2014related by meaning
    ed a ruling that the division of IRA C and subsequent transfer of the amount specified in the divorce decree to IRA E will be considered a non-taxable transfer and will not be considered a modification of the SEPP for purposes of section 72(t)(4) of the Internal Revenue Code (the Code). 2 .201484030 Applicable Law and …
  10. T.C. Summary Opinion 2003-59 — Anthony V. & Sandra K. Margavio v. Commissioner
    IRCCourt RulingsMay 22, 2003
    …tioners timely filed a 1998 Federal income tax return. On the 1998 return, petitioners reported $32,628 on Line 16a, Total pensions and annuities, and $15,715 on Line 16b, Taxable amount. For the taxable year 1998, the Teachers’ Retirement System of Louisiana issued to petitioner a Form 1099-R (Form 1099-R), Distributi…
  11. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998
    …50-percent interest in two parcels of unencumbered real estate. The market value of one parcel was $628,000 on Sept. 23, 1991. The market value of the other parcel was $1.45 million on Nov. 9, 1991. Held : P's transfer of property to his plan was a "sale or exchange" under sec. 4975(c)(1)(A), I.R.C.; hence, it was a pr…
  12. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  13. Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”…
    IRCRevenue ProceduresOct 15, 2018
    ….06 Special rules relating to Excess Amounts 626 .07 Rules relating to reporting plan loan failures 628 .08 Correction under statute or regulations 628 .09 Matters subject to excise or other taxes 628 .10 Correction for 403(b) Plans 629 .11 Correction for SEPs and SIMPLE IRA Plans 630 .12 Confidentiality and disclosure…
  14. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  15. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …S.C. section 1983. But see Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc. , 473 U.S. 614, 628 (1985) (arbitration presumptively competent to resolve certain other statutory claims). Such cases remind us that rules about preclusion are usually judge-made default rules--rules that can be upended when “Congress …
  16. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  17. 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 …
  18. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    stitute an investment in the contract and, therefore, petitioner may not exclude those payments from the $182,481.39 distribution he received in 1983. We agree with respondent’s conclusions. In particular, we hold that, absent the statutory modifications enacted in 1984 (discussed infra), petitioner is the distributee …
  19. 76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes
    IRCFinal Rules (FR)Jun 24, 2011
    …n); 233 hours (Internal Revenue Service) (three-year average). Estimated Total Annual Burden Cost: $628,900 (Employee Benefits Security Administration); $628,900 (Internal Revenue Service) (three-year average). 2. Department of Health and Human Services a. ICR Regarding Affordable Care Act Internal Claims and Appeals a…
  20. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…