IRCCourt RulingsMay 19, 2011
…ngly, we sustain respondent's
determination that Weekend Warrior has forgone interest income of
$39,896 and $71,680 for 2002 and 2003, respectively.
The foregoing c¯onclusion results in the corollary conclusion
that in 2002 Mr. Warmoth had constructive dividend income of
$39,896." Petitioners do not rely on any facts o…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976★ strong match
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 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…
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 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…
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…
85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 7, 2020
…nthly benefit at URA is—
High 4
if monthly
benefit at URA
is greater than—
From—
To—
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
2029
804
804
3,396
3,396
2030
822
822
3,474
3,474
2031 or la…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsJan 14, 2013
… 1,169,540 22,903 18,346 41,249
1998 1,238,596 44,632 30,033 74,665
1999 1,265,554 81,916 12,980 94,896
83 FR 63802 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 12, 2018
… at
URA is
greater than—
From—
To—
2020
655
655
2,767
2,767
2021
670
670
2,831
2,831
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
2029 or later
804
804
3,396
3,396
1
Applicable tables for v…
80 FR 74986 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2015
…647
2,647
2018
640
640
2,705
2,705
2019
655
655
2,767
2,767
2020
670
670
2,831
2,831
2021
686
686
2,896
2,896
2022
701
701
2,962
2,962
2023
718
718
3,030
3,030
2024
734
734
3,100
3,100
2025
751
751
3,171
3,171
2026 or later
768
768
3,244
3,244
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington,…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…at the quid was adoption services provided by
33
[* 33] the donee); DeJong v. Commissioner, 36 T.C. 896, 899 – 900 (1961)
( determining that the quid was education services provided by the
donee), aff ’ d , 309 F.2d 373 (9th Cir. 1962). Nor did the Board of
Supervisors compel the donation to a donee of its choice. Cf. …
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…5
30
1,307,700
167.48
219,013,596
Plan MEWAs that are not fully insured
132
15
60
118,800
167.48
19,896,624
Non-plan MEWAs that are not fully insured
21
15
60
18,900
167.48
3,165,372
First-year Total
10,021
15
5,877,000
984,279,960
Subsequent Years
Issuers (health insurance company/State combinations)
1,467
15
12
264,0…
IRCCourt RulingsMar 5, 2018related by meaning
stock. But in substance there was an established expectation and intention
that commission payments would be made, and the Roth IRAs were directed to purchase the FSC stock on the basis of that expectation and intention. The formal
basis for the purchase price therefore did not reflect the substance of the relatedpart…
IRCRegulationsSep 9, 2016
…rmined using the 5.5 percent interest and the section 417(e)(3) applicable mortality table) is $498,896 and the actuarial present value of the single life annuity is $497,876. Accordingly, the specific information discloses that the single-sum distribution has a value that is 45 percent of the value of the single life …
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…First year
Subsequent years
First year
Subsequent years
PTE 84-24
$17,425,393
$14,733,328
$3,425
$2,896
PTE 2020-02
227,505,836
194,922,497
18,029
2,757
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…-for-profit institutions.
Respondents:
399,269.
Responses:
5,645,697.
Estimated Total Burden Hours:
896,142.
Estimated Total Costs:
$5,927,982.
Description:
Pursuant to section 401(a) of the Child Support Performance and Incentive Act of 1998 (CSPIA),[95]
the Department of Labor (the Department) and HHS jointly promulg…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… Matthew A. Unruh, et al.,
Physician Turnover in the United States,
175 Annals of Internal Medicine 896, 903 (2023).
Back to Citation
152.
See Table 3 for an example.
Back to Citation
153.
For the purposes of this section III.C.11, the term “health insurance market” refers to the definition in proposed 25 CFR 54.9815…