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 19, 1986★ strong match
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
…is results in an annual hour burden of approximately 21,603 hours with an equivalent cost of $1,425,549 104 The Department expects that the results would be provided electronically and thus does not expect there to be any material costs with providing Independent Producers with the retrospective review.
( printed page …
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…following calculation: (259,230 retrospective reviews × (5 minutes ÷ 60 minutes)) × $65.99 ≉ $1,425,549. Note, the total values may not equal the sum of the parts due to rounding.
Back to Citation
761.
The annual cost is estimated as: ($42,957,003 to conduct the retrospective review + $190,594 for the review of the re…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
IRCCourt RulingsJun 17, 1997
…. 5754-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1)
6662(a)
1989 $12,744 $637 $2,549
Howard S. Young & Elaine P. Young (the Youngs),
docket No. 5755-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1)
6662(a)
1989 $14,008 --- $2,802
Bruce E. Traegde & Patricia Traegde (the Traegdes),
dock…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
g at the time of
retirement”. G en. Signal Corp. v. Commissioner
, 142 F.3d at 549
(citing Parker-Hannifin Corp. v. Commissioner
, 139 F.3d 1090, 1094 (6th Cir. 1998)). We agree with respondent that the funding of the
reserve cannot begin until the reserve is created. However, we do
not agree with respondent that the r…
IRCCourt RulingsFeb 18, 2004
…adhered to the $6,154.94 penalty that
petitioners self-assessed on their amended return for the
$61,549.38 taxable portion of early distributions by Southern
Farm Bureau and Glenbrook.. Respondent included the previously
unreported SFB and Glenbrook distributions as gross income,
determined that self-employment tax was…
IRCCourt RulingsSep 25, 1996
…ership taxable income of
$840,069 for 1987. This consisted of $637,316, one-fourth of the
- 45 -
$2,549,264 deferred income that it was allocating over 4 years,
plus $231,253 in accrued interest payable from MPC, less
$28,500--a management fee expense to BBPA.
On its partnership return for 1988, MIT 82 reported
partner…
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
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 RulingsJan 14, 2013related by meaning
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
…inesses or other for-profits, Not-for-profit institutions.
Respondents:
809,901.
Responses:
178,211,549.
Estimated Total Burden Hours:
1,068,322.
Estimated Total Costs:
$18,423,119.
Descriptions:
IRCCourt RulingsMar 24, 1980
…,100
1966. 9,235
Year Cash dividends
1967. $10,844
1968. 17,800
1969. 20,399
1970 . 27,988
1971. 63,549
1972. 1,800,274
1973 . 313,863
1974 . 470,495
1975 . 544,895
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…
IRCCourt RulingsMay 23, 1979★ strong match
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
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…
38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner IRCCourt RulingsSep 21, 1962
…ution was adopted: Whereas, the books oí account of the Exchange now show that the Exchange had $55,549.11 on hand as of December 31, 1944, oyer and above the cost of insurance subscribers, and it is deemed to be to the best interests of the subscribers that said sum be distributed pro rata in cash to the subscribers o…
IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…