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76 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …(A × B) (A × B × C) Notice Preparation (Service Providers) 3,552 Service Providers 1 $181.06 3,552 $643,125 Notice Preparation (In-House) 26,301 = 263,006 Small Plans × 10% Not Using a Service Provider 1 181.06 26,301 4,761,983 ( printed page 9233) Adding Contact and Plan Information to Drafted Notices 236,705 = 263,00…
  2. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000★ strong match
    end of that year, the conversion credit balance was $17,643.01 ($8,603.71 + $10,530 - $2,250.45 + $759.75); the $759.75 is the interest of 4.5 percent earned on the conversion credit balance (($17,643.01 - $759.75) x 4.5% = $759.75)). Of the conversion credit balance, $8,380.43 could have been transferred at this time …
  3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    e was “intertwined with the merits,” i.e., with the question of whether petitioner had actually made “excess contributions” reportable on Form 5329. 5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of law from asserting excise tax liability u…
  4. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    ,643 disclosures × 5 minutes) ÷ 60 minutes] = 15,387 hours. [(184,643 disclosures × 5 minutes) ÷ 60 minutes] × $63.45 = $976,301. Back to Citation 48.  The material and postage cost is estimated as: (184,643 disclosures × 4 pages × $0.05) + (184,643 disclosures × $0.66 postage) = $158,793. Back to Citation 49.  Departm…
  5. 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…
  6. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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 …
  8. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    … citation of United States v. Craft, 535 U.S. 274, 283, 288 (2002), and Notice 2003-60, 2003-2 C.B. 643, 645. S_e_e dissenting op. p. 89. As we have explained, see supra note 25, as of the time of the CDP hearing Mr. Melasky cannot possibly have held the Exxon Mobil stock as a tenant by the entirety. We also do not und…
  9. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
  10. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    or was the filing fee paid. See Rule 173(a). The Court ordered petitioners to file a proper amended petition and pay the filing fee by May 2, 2003. 13 Petitioners timely filed an amended petition with the Court and paid the filing fee. In the amended petition, petitioners disputed deficiencies determined for taxable ye…
  11. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  12. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …,225 in subsequent years. The three-year average cost burden associated with OPM requirements is $6,643. The Departments seek comment on the assumptions and calculations made in this ICR. Table 33—HHS Summary Cost and Burden of IDR Entity Certification Starting in 2022 Estimated number of responses Total annual burden …
  13. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015
    …nd intention in engaging in the activity is to make a profit. Dreicer v. Commissioner, 78 T.C. 642, 643 (1982), aff'd without published opinion, 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of profit need not be a reasonable one, but merely bona fide. Id ; sec. 1.183-2(a), Income Tax Regs. Whether a taxpa…
  14. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  15. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …9 William Shaw V.P. Sales & 85,000 651,997 736,997 Marketing Jim Discher Sr. Acct. Exec. 25,000 370,643 395,643
  16. 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…
  17. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  18. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …nvestors receiving paper disclosures is estimated as: (3,183,503 retirement investors × 5.8%) = 184,643 paper disclosures. Back to Citation 479.  The cost is estimated as: (184,643 paper disclosures × 2 pages) × $0.05 = $18,464. Back to Citation 480.
  19. Treas. Reg. § 1.72-7(e) — Adjustment in investment where a contract contains a refund feature.
    IRCRegulationsJul 26, 2016
    …'s allocable portions of the investment in the contract after adjustment for the refund feature $76,643.18 Exclusion ratio for the contract as a whole (total adjusted investment in the contract, $76,643.18, divided by the total expected return from above, $134,580.00) (percent) 56.9
  20. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …d returns showed income as follows: 1999 2000 2001 2002 2003 Gross Income $630 ,054 $862,338 $1,990,643 $3,105,883 $2,836,896 Total Expenses 573,086 856,475 1,695,246 2,818,055 2,775,227 Net Income 56,968 5,863 295,397 287,828 61,669 For 2004, Special Agent Trogden examined the bank records of four bank accounts titled…