T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…sufficient market data for
comparable properties. See Whitehouse Hotel Ltd. P’ship v.
Commissioner, 139 T.C. 304 , 324 – 25 (2012) (holding that other
valuation methods are “not favored if comparable- sales data are
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…
PBGCRegulationsJan 1, 2017★ strong match
[Reserved]
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…g cost if using
permitted practices
(A)
(B)
(C)
(D)
(E)
(F)
(G)
(H)
(I)
Providers: PP
1,988
8,020
139,973,458
3,499,336
233,289
$409,291,139
$25,751,617
$435,042,756
Providers: Non-PP
1,988
8,020
8,303,510
830,351
27,678
97,119,931
3,055,277
100,175,208
100,175,208
Total
1,988
148,276,968
4,329,687
260,967
506,411,07…
IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsSep 25, 2009
…has as its basic function
the systematic liquidation of the principal.” Se e also Comm’r v. Meyer , 139 F.2d 256
(6th Cir. 1943). Similarly, in Rev. Rul. 75-255, 1975-2 C.B. 22, the Service observed
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…g future revenue.” Excelsior Aggregates, T.C. Memo. 2024-60,
at *43 – 44 (citing Whitehouse Hotel , 139 T.C. at 325 ( observing that the
income approach “has been judged an unsatisfactory valuation method
for property that does not have a track record of earnings”)); see also J L
Mins. , T.C. Memo. 2024-93, at *61 . Th…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…ith 50
participants
Plans with 75
participants
Plans with 100
participants
Plan Premiums by Size *
$139,440
$348,600
$697,200
$1,045,800
$1,394,400
Cost per Plan
$2.30
$5.30
$10.30
$15.30
$20.30
Total
0.0016%
0.0015%
0.0015%
0.0015%
0.0015%
* Plan Premiums are obtained by average annual premiums per covered participant…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…
4,949,140
5,154,737
81,890,909
2
57.3
42.7
38.8
0
0
0
4,471,532
4,471,532
3
60.2
39.8
35.9
0
0
0
4,139,119
4,139,119
4
61.7
38.3
34.4
0
0
0
3,977,383
3,977,383
5
62.3
37.7
33.8
0
0
0
3,898,691
3,898,691
6
62.7
37.3
33.4
0
0
0
3,860,403
3,860,403
7
62.8
37.2
33.3
0
0
0
3,841,774
3,841,774
8
62.9
37.1
33.2
0
0
0
3,832,7…
Notice 2025-60 — This notice sets forth the 2025 Required Amendments List (2025 RA List). The 2025 RA List applies to individually designed plans qualified under section 401(a)… IRCNoticesDec 22, 2025
… transition rule for dividends (the “transition rule”) in section 70354(c)(2) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act. The transition rule modifies the application of section 951(a)(2)(B) of the Internal Revenue Code for certain taxable years of foreign corp…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJun 11, 1996★ strong match
rary purpose has been shown here.
Because we are satisfied that our analysis of section
4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain
respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A.
- 11…
IRCProposed Rules (FR)Proposed May 13, 2026
…Issuers
811
Group Health Plans and Sponsoring Employers
522,811
Participants and Eligible Employees 139
54,411,264
Participants and Eligible Employees Likely to Enroll
743,361
The
Departments seek comments on the number of entities that would be affected by these proposed rules. In particular, the Departments seek comm…
87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption) ERISAProposed Rules (FR)Proposed Jul 27, 2022
…stimates that the cost burden for preparing and mailing the notices will be approximately equal to $139, that is, 205 * ((2 * $0.05) + $0.58) = $139 (rounded). Therefore, the total cost associated with this requirement is (4 * legal professional labor rate of $140.96) + (7 * clerical labor rate of $55.23) + $139 = $1,0…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
ERISAProposed Rules (FR)Proposed Jul 21, 2016
5 or Fewer
0.088
0.091
178,694
6-10
0.084
0.087
105,458
11-25
0.067
0.070
139,971
26-50
0.040
0.041
86,936
51-75
0.022
0.023
38,822
76-90
0.018
0.018 14,491
90-99
0.016
0.016
6,341
Defined Benefit Pension—Not Eligible for 5500-SF:
5 or Fewer
0.002
0.003
566
6-10
0.050
0.086
82
11-25
0.041
0.069
60
26-50
0.016
0.027
40…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…djusting menus prior to the 2015 ruling, cautioning that the analysis may underestimate the effect.[139]
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…