IRCCourt RulingsJan 31, 1973★ strong match
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsAug 11, 1980
…lesser pension contributions in the discrimination area. In Container Service Co. v. United States, 345 F. Supp. 235 (S.D. Ohio 1972), affd. per curiam on other grounds 478 F.2d 770 (6th Cir. 1973), the taxpayer, attempting to prove nondiscrimination, argued that the only employees excluded from its corporate profit-sh…
IRCCourt RulingsNov 17, 2016related by meaning
culating the required reduction in the section 415 dollar limitation.
Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the
age 45 limits for tax years 2002 through 2006 are correct.
III. Petitioner's Liabilit…
IRCCourt RulingsMay 23, 1979related by meaning
oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
IRCCourt RulingsAug 30, 1993related by meaning
ding standard under section 412(d) but chose not to do so. We sustain respondent's determination of petitioner's section 4971(a) excise tax liability. FYE 1987 Employer ReversionSection 4980(a) imposes a 10-percent tax on the amount of any employer reversion from a qualified plan. The term "employer reversion" is defin…
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…
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
…before reaching the age at which a Federal Benefit Payment is payable to the individual. Section 29.345 provides the rules for adjustments of Federal Benefit Payments after the initial calculation. Under current section 29.345, cost-of-living increases are applied directly to Federal Benefit Payments. The paragraph is …
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 …
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ies and Procedures:
Total
146,328
595,837
662,103
12,041
3,453
321,138
6,906
Per-Entity
80
80
80
80
345
345
345
Retrospective Review:
Total
6,043
562,032
12,087
Per-Entity
604
604
604
( printed page 75971)
Total:
Total
20,078,016
81,756,286
90,848,839
1,660,214
119,169
11,082,746
238,339
Per-Entity
696
696
696
749
1,67…
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 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… on employer costs and patients' out-of-pocket costs remain uncertain. These mechanisms are opaque,[345]
and the variability in how they are implemented across self-insured group health plans contributes to significant uncertainty about their financial impact on patients. For example, copay clawbacks are difficult to i…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
345 each. As shown in Table 26, the hour burden associated with OPM requirements is estimated to be approximately 1 hour at an equivalent cost of $69. ( printed page 56074)
Table 24—HHS's Annual Burden and Costs Request an Extension of Times Periods for Extenuating Circumstances Starting in 2022
Estimated number of res…
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 RulingsSep 18, 1996related by meaning
begin with section 4973.
Section 4973
Section 4973(a) imposes a 6-percent excise tax on excess
contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as
a deduction under section 219 (computed without regard to section
- 27 -
219(g)), exclusive of amounts p…
IRCCourt RulingsMar 25, 2013
…ertens, Law of Federal Taxation, sec. 5A.11, at 22
(1998 rev.); see also Smith v. Manning, 189 F.2d 345 (3d Cir. 1951);
Sterno Sales Corp. v. United States, 170 Ct. Cl. 506, 345 F.2d 552
(1965); Reynard Corp. v. Commissioner, 30 B.T.A. 451 (1934);
Mosby v. Commissioner, T.C. Memo. 1984-90; Zeunen Corp. v.
United States…
IRCCourt RulingsJun 11, 1996related by meaning
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…
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…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
….B. 2026-21 1502
Proposed Regulations:
Article Issue Link Page
REG-101952-24 2026-03 I.R.B. 2026-03 345
IRCCourt RulingsMar 31, 1961
…ty:
Unseparated product at $4.99/ton_ $568, 765. 19 $179, 729. 80 $389, 035. 39
Byproduct sales_ 1, 345. 05 1, 345. 05
Less royalties_ 22, 895. 89 7, 235. 10 15, 660. 79
Adjusted gross income_ 547, 214. 35 172, 494. 70 374, 719. 65
Direct costs_ 440, 229. 89
Adm. prorated_ 21, 850. 24
Net income_ 85, 134. 22
50% of net…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…