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81 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    ........................... 13 D. Management Agreement ............................... 13 E. Shareholders' Agreement............................... 13 F. Compliance Guide .................................... 14 IV. Operations ofthe FSC/IRA Program.......................... 15 V. Procedural Background ..................…
  2. 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 …
  3. T.C. Memo. 1995-594 — Steven M. & Michele E. Grow v. Commissioner
    IRCCourt RulingsDec 14, 1995
    …in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-594 UNITED STATES TAX COURT STEVEN M. AND MICHELE E. GROW, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20185-94. Filed December 14, 1995. Steven M. and Michele E. Grow, pro se. Amy Dyar Seals …
  4. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995★ strong match
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
  5. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  6. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  7. T.C. Summary Opinion 2017-43 — Richard Lee Fann & Beverly Selena Fann v. Commissioner
    IRCCourt RulingsJun 28, 2017
    …ent they exceed 7.5% of adjusted gross income. Petitioners' adjusted gross income for 2012 was $156,594, and they paid $8,939 in unreimbursed medical expenses that year. Because petitioners' unreimbursed medical expenses did not exceed $11,744 (7.5% of $156,594)--the floor for an allowable deduction under section 213--…
  8. 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…
  9. T.C. Summary Opinion 2014-94 — Kenneth Russell Laremore v. Commissioner
    IRCCourt RulingsSep 18, 2014
    Commissioner, T.C. Memo. 1990-540, 1990 Tax Ct. Memo LEXIS 594, the Court was asked to decide whether an obligation containing the phrase "the Husband shall pay" created an obligation which survived the death of the recipient spouse. Highlighting the fact that "the statute speaks in terms of 'liability'", we held that …
  10. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …erstand that the city annuity paid to petitioner an additional $5,890.28 (gross distribution of $11,594.84 less $5,493.48 payments received under the city annuity less employee contribution or insurance premium of $211.08). -10Form 1099-R issued to petitioner by the Trust is consistent with our analysis. That form repo…
  11. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997
    …tion of all surrounding facts and circumstances. American Offshore, Inc. v. Commissioner , supra at 594. Generally, a taxpayer may establish - 5 - the worthlessness of a debt by offering proof of identifiable events which establish that the debt will not be paid in the future. Therefore, a taxpayer's subjective opinion…
  12. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …ective review. This results in an annual hour burden of 1,430 hours with an equivalent cost of $190,594.103 Table 12—Hour Burden and Equivalent Cost Associated With the Certification by the Senior Executive Officer Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burden hours Equivalent burden cost …
  13. Treas. Reg. § 1.72-16(c)(3) — Life insurance contracts purchased under qualified employee plans.
    IRCRegulationsJul 26, 2016
    …return, 10 × $1,320 $13,200 Exclusion ratio, $5,940 ÷ $13,200 0.45 Annual exclusion, 0.45 × $1,320 $594 Accordingly, $594 of the $1,320 portion of each annual installment is excludable each year under section 72, and the remaining $726 is includible. Thus, if the beneficiary is not a surviving spouse, a total of $1,006…
  14. 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…
  15. 89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Oct 28, 2024
    …yers, plans and issuers. See fn. 24. Back to Citation 159.  The Departments estimate that there are 594,404 ERISA-covered self-insured group health plans based on data from the 2022 Medical Expenditure Panel Survey Insurance Component (MEPS-IC) and the 2020 County Business Patterns from the Census Bureau. The 2020 KFF …
  16. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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.…
  17. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …rceable obligation to pay a fixed or determinable sum of money." Kean v. Commissioner, 91 T.C. 575, 594 (1988); sec. 1.166-1(c), Income Tax Regs. A gift is not considered a "debt" for purposes of section 166. Kean v. - 20 - [*20] Commissioner, 91 T.C. at 594. Whether a purported loan is a bona fide debt for tax purpose…
  18. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …uarial present value of projected benefits Active employees $13,361,586 $38,521,857 $62,860,146 $83,594,015 Retired employees 26,311,902 36,694,928 47,731,960 48,947,859 Total 39,673,488 75,216,785 110,592,106 132,541,874 2. Actuarial value of assets VEBA -0- 30,736,554 30,176,217 39,940,676
  19. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    … and entertainment expenses as follows: Year Advances Vouchers Difference 1971 .$6,900 $4,305.55 $2,594.45 1972 . 19,250 9,028.00 10,222.00 1973 . 20,500 7,724.67 12,775.33 25,591.78 Respondent determined that the following amounts Huffaker received from Ma-Tran during these years constituted dividend income: 1971 1972…
  20. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    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’ …