IRCCourt RulingsJul 8, 2020
…ouse $19,092 during 2016, consisting of $9,283 distributed to Morehouse from her 529 account and $9,809 in
payments separately documented by her bank statements. We find that $5,816 of
the latter sum represented the balance of her withdrawals from the section 529
account (viz., the portion distributed to her rather tha…
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 …
PLR 201128017 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 15, 2011
…Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494 (1984), the controlling provision
was § 809(c)(1). Thi s provision was interpreted by § 1.809-4(a)(1)(i), which provided
that
The term “gross amount of all premiums” means the
premiums and other consideration provided in the insurance
or annuity contract. Thus…
PLR 201105005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsFeb 4, 2011
…fer of property in an assumption
reinsu rance transaction as defined in paragraph (a)(7)(ii) of § 1.809-5). The term also includes amounts a life insurance
company charges itself representing premiums with respect
to liability for insurance and annuity benefits for its
employees (including full-time life insurance sale…
IRCCourt RulingsJul 6, 2010
…petitioner received distributions totaling'$60,937 as follows :
$24,689 from account No . 8052, $18,809 from account No . 9853,6
and $17,439 from account No . 9052 .' In 2006 petitioner was not
yet 59-1/2 years old .
Petitioner filed her 2006 Form 1040 ., U .S . Individual Income
Tax' Return, -electronically ."' Petiti…
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 RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
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 RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
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…
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 RulingsMar 10, 2020
…ation for the statutory distinction. McDonald v. Board of
Election Com'rs of Chicago, 394 U.S. 802, 809 (1969).
Estate of Kunze v. Commissioner, 233 F.3d 948, 954 (7th Cir. 2000), § T.C.
Memo. 1999-344.5
This Court follows the same framework in evaluating equal protection
claims regarding statutes affecting economic ri…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…0-0040.
Affected Public:
Businesses or other for-profits, Not-for-profit institutions.
Respondents:
809,901.
Responses:
178,211,549.
Estimated Total Burden Hours:
1,068,322.
Estimated Total Costs:
$18,423,119.
Descriptions:
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsJul 23, 1981
…aph (B)).” Sec. 2(3), Self-Employed Individuals Tax Retirement Act of 1962, Pub. L. 87-792,76 Stat. 809,811. For an explanation of the effect of sec. 911(b) on "earned income” under present law as compared with prior law (prior to sec. 204(c), Foreign Investors Tax Act of 1966, Pub. L. 89-809,80 Stat. 1539,1577, effect…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…e will affect 205 TPAs and 373 issuers (
i.e.,
health insurance companies) in the group market with 809 issuers/State combinations [211]
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAProposed Rules (FR)Proposed Oct 14, 2021
…ct and Indirect
941
586
1,527
1
1,528
Total
5,005
20,463
25,468
573
26,041
ESOP (No Common Stock)
5,809
5,809
5,809
Common Stock and ESOP
591
591
591
Total All Plans Holding Stocks
5,005
26,863
31,868
573
32,441
a
DOL calculations from the 2018 Form 5500 Pension Research Files.
There are approximately 629,000 small pe…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…ct and Indirect
849
645
1,494
1
1,495
Total
4,558
19,564
24,122
518
24,640
ESOP (No Common Stock)
5,809
5,809
5,809
Common Stock and ESOP
574
574
574
Total All Plans Holding Stocks
4,558
25,947
30,505
518
31,023
a
DOL calculations from the 2020 Form 5500 Pension Research Files.
There are approximately 652,900 small pe…