IRCCourt RulingsJun 17, 1996
…at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1996-278
UNITED STATES TAX COURT
DONALD G. RUSSELL, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12946-95. Filed June 17, 1996.
Donald G. Russell, pro se.
Gary W. Bornholdt
, for respondent.
MEMORAND…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsFeb 9, 2023★ strong match
…parties’ own stipulations
make it clear that Treasury reviewed the comments.” See concurring op. p. 278. The
concurring opinion “take[s] it a step further and argue[s] that [blanket statement in]
the preamble [that the comments were considered] is sufficient to respond to the four
comments regarding the proposed blocke…
IRCCourt RulingsMar 6, 2001
…suffer undue damage by imposition of
- 26 -
the liability.’” Purer v. United States
, 872 F.2d 277, 278 (9th
Cir. 1989) (quoting Wagner v. Director, Fed. Emergency Mgmt.
Agency
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…74
2021
116,709 * (Additional burden for Subset of Physicians with Websites)
* 116,709
1
116,709
13,278,038
Total
3.5
481,426
** 75,075,712
* This is calculated as the sum of $61,797,674 (cost for all individual physician practitioners to draft notice of right to GFE) + $13,278,038 (cost for computer programmers to pos…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…6 (6th Cir. 2022);
see also Matousek
( printed page 16091)
v.
MidAmerican Energy Co.,
51 F.4th 274, 278 (8th Cir. 2022) (noting that for the duty of prudence, “[t]he process is what ultimately matters”). Thus, prudence is assessed based on a fiduciary's investigation at the time of the investment decision, and not in h…
IRCCourt RulingsAug 28, 2014
…ldren.
II. Retirement Account Loan and Distributions Sometime before 2011 Mr. Matthews borrowed $36,278 from his 401(k)
plan account. During 2011, shortly after losing his job with Synapse,
Mr. Matthews requested a distribution of $128,140 from his 401(k) plan account.
He understood that his loan would have to be repai…
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 RulingsDec 18, 2012★ strong match
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
81 FR 80002 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Nov 15, 2016
…)
On or
after
Before
i1 i2
i3
n1
n2
* * * * * * *
278
12-1-16
1-1-17
0.75
4.00
4.00
4.00
7
8
( printed page 80003)
3. In appendix C to part 4022, Rate Set 278, as set forth below, is added to the table.
Appendix C to Part 4022—Lump Sum Interest Rates For Private-Sector …
IRCRegulationsSep 9, 2016
…000 Net adjustments: 1988 40,500 40,500 40,500 1987 38,500 38,500 1986 44,500 Total 273,500 275,500 278,500 228,000 Average value: 1988 = $273,500 + $275,500 + $278,500 + $228,000 ÷ 4 = $263,875 (ii) Plan F properly determines an average value under paragraph (b)(7) of this section for use as an actuarial value. Theref…
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…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
278” and paragraph (b)(2) by removing “$54,910” and adding in its place “$55,808”.
PART 578—MINIMUM WAGE AND OVERTIME VIOLATIONS—CIVIL MONEY PENALTIES 17. The authority citation for part 578 continues to read as follows:
Authority:
Sec. 9, Pub. L. 101-157, 103 Stat. 938, sec. 3103, Pub. L. 101-508, 104 Stat. 1388-29 (2…
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…
IRCCourt RulingsAug 10, 2015
…l of
petitioner's deductions should be disallowed.
- 11 -
Dagres v. Commissioner, 136 T.C. 263, 277-278 (2011); see also Papineau v.
Commissioner, 28 T.C. 54, 57 (1957). New matter includes a new theory that
"'alters the original deficiency or requires the presentation of different evidence.'"
Dagres v. Commissioner, 1…
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’ …
IRCCourt RulingsDec 19, 1974
…tioner, as decedent’s designated beneficiary (section 9 of the plan) received a distribution of $15,278.49, representing decedent’s entire interest in the assets of the plan. Of this amount, $5,317.50 represented decedent’s contributions which were nontaxable under section 402(a) and the remaining $9,960.99 represented…
IRCCourt RulingsFeb 29, 2012
…e to be taken as the final expression of the
meaning intended." United States v. Mo. Pac. R.R. Co., 278 U.S. 269, 278 (1929).
Thus we look to the specific language of the statute to determine whether it is
clear and unambiguous.
Both respondent and petitioner argue that section 4980(c)(1)(A) is clear and
unambiguous. H…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…