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 …
IRCCourt RulingsDec 18, 2012
…for the subject years includes
nonemployee compensation of $483,591, $487,873, $536,145, $628,500,
$694,986, and $815,963, respectively, that Ms. Zaklama realized from her selfemployment, and whether petitioners may deduct self-employment business
4We decide these issues bearing in mind that issues and arguments not
ad…
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…
IRCRegulationsSep 9, 2016
… The excess of the death benefit over Participant A's accrued benefit as of January 1, 2010, is $20,694 (that is, $70,361 − $49,667). Because this part of the death benefit is not a function of Participant A's accrued benefit or service, the portion that is taken into account in determining the funding target is determ…
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 RulingsAug 17, 2015
…return on October 12, 2011, reporting retirement income of $152,997. They thus failed to report $71,694 of retirement plan
distributions. Petitioners claimed various itemized deductions on their return,
including medical expenses of $78,955 and "miscellaneous deductions" of
$18,779.
Respondent's "automated underreporte…
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 …
IRCCourt RulingsMar 31, 2015
…ket value of the sec.
401(k) plan account by 30%. Income Table
Item Claimed¹ Appeals
Gross wages $6,694 $8,202
Social Security -0- 459
Total 6,694 8,661
'This column reflects the income that
petitioners claimed on their Form 433-A.
- 10 -
[*10] Expense Table
Expense Claimed¹ Appeals
National standard $1,021 $1,450
Hous…
IRCCourt RulingsMar 12, 2008
…0 9,294 112,97 5 23 112,975 25,000 87,975 8,038 96,01 3
24 96,013 25,000 71,013 6,681 77,69 4
25 77,694 25,000 52,694 5,216 57,90 9
26 57,909 25,000 32,909 3,633 36,54 2
27 36,542 25,000 11,542 1,923 13,46 6
We note four preliminary points about petitioner's
calculation . First, the annual account balance is reduced by…
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…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
… 29,584, respectively. The total number of examination parts provided during the three years was 86,694. The IRS used this historical three-year volume to estimate the number of examination parts it expects to provide in FYs 2026, 2027, and 2028. Dividing this total cost by the projected examinations for FYs 2026 throu…
IRCCourt RulingsJul 15, 1997
…xable Year Ending
Original Return
Amended Return
June 30, 1986 $446,781 no change
June 30, 1987 379,694 $364,694
Dec. 31, 1987 49,782 181,718
Dec. 31, 1988 430,002 no amended return filed
On their Federal income tax returns and amended return,
petitioners included in their gross income compensation payments
from the co…
ERISACourt RulingsSep 17, 2026
…n A. Garner, Reading Law 170–71 (2012)); see Servotronics, Inc. v. Rolls - Royce PLC, 975 F.3d 689, 694–95 (7th Cir.
2020) (“Identical words or phrases used in different parts of
the same statute … are presumed to have the same meaning.”).
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 RulingsMay 9, 1988
…tirement Fund v. Commissioner, T.C. Memo. 1982-594, affd. sub nom. Wenzel v. Commissioner, 707 F.2d 694 (2d Cir. 1983).
IRCCourt RulingsApr 26, 2005
…s v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must decide
whether the Commissioner, in making a determination as to the
- 11 -
initial or continuing qualification of a retirement pla…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ts
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
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…lowing calculation: [189,428 reviews by small entities × (5 minutes ÷ 60 minutes)] × $65.99≉ $1,041,694.
Back to Citation
857. This burden is the combination of: $31,390,045 to conduct the review + $139,273 to review and certify the review + $1,041,694 to provide review results to Independent Producers ≉ $32,571,012.
…
IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Oct 28, 2024
…ponding to these calls would be 41,800 hours, with an equivalent total cost of approximately $1,915,694 as shown in table 7.
Table 7—Estimated Annual Cost and Hour Burden for All Issuers and TPAs To Respond to Calls Regarding the New Contraceptive Statement on the Internet-Based Self-Service Tool
Number of respondents
…