120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
10,592,106 132,541,874
C. Value of assets (beginning of year)
a. VEBA --- 30,736,554 30,176,217 39,940,676
b. 401(h) --- 1,125,467
1,172,269
7,598,653 c. Total --- 31,862,021 31,348,486 47,539,329
D. Nondeductible contribution from prior
years (O from prior year) --- 22,034,781 14,394,743 14,426,384
E. Net value of ass…
88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023
l not affect the remainder thereof.
* * * * *
9. Section 2590.736 is revised to read as follows:
( printed page 44655)
§ 2590.736
Applicability dates. Sections 2590.701-1 through 2590.701-8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Until the applicability dates set …
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…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
agraph (c)(4) and shall not affect the remainder thereof.
* * * * *
8. Section 2590.736 is revised to read as follows:
§ 2590.736 Applicability dates. Sections 2590.701–1 through 2590.701–8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Notwithstanding the previous sente…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…nder of this paragraph (c)(4) and shall not affect the remainder thereof.
* * * * *
8. Section 2590.736 is revised to read as follows:
§ 2590.736
Applicability dates.
Sections 2590.701-1 through 2590.701-8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Notwithstanding th…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…0
1
51.3
48.7
44.8
60,610,921
20,656,573
5,639,871
47,024,610
133,931,975
2
57.3
42.7
38.8
0
0
0
40,736,877
40,736,877
3
60.2
39.8
35.9
0
0
0
37,677,581
37,677,581
4
61.7
38.3
34.4
0
0
0
36,189,080
36,189,080
5
62.3
37.7
33.8
0
0
0
35,464,850
35,464,850
6
62.7
37.3
33.4
0
0
0
35,112,476
35,112,476
7
62.8
37.2
33.3
0
0
…
IRCCourt RulingsSep 24, 2007related by meaning
T .C . Memo . 2007-292
UNITED STATES TAX COUR T
HUBERT JOUBERT, Petitioner V .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 8769-06 . Filed September 24, 2007 .
P failed to file a Federal income tax return for 2002 .
R determined a deficiency and asserted in the notic e
deficiency, the answer, and the pret…
IRCCourt RulingsApr 2, 2024
…islative history, “but
its language could scarcely be more explicit,” Bob Jones Univ. , 416 U.S.
at 736. The Supreme Court has interpreted the principal purpose of the
AIA as the “protection of the Government’s need to assess and collect
taxes as expeditiously as possible with a minimum of preenforcement
judicial inter…
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 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 RulingsJul 9, 1997
…elies on three Tax Court cases and one Second Circuit case,
Gilford v. Commissioner
, 201 F.2d 735, 736 (2d Cir. 1953), affg.
a Memorandum Opinion of this Court, and attempts to distinguish
Grier
from this case.
In Gilford
, the taxpayer inherited fractional interests in
several buildings in the 700 block of Third Aven…
IRCCourt RulingsNov 12, 1997
…t the law firm,
petitioner has not shown that he is entitled to a loss deduction in
1991.
Section 1.736-1(a)(1)(ii), Income Tax Regs., provides:
A partner retires when he ceases to be a partner under
local law. However, for purposes of subchapter K,
chapter 1 of the Code, a retired partner or a deceased
pa rtner's succ…
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 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…
IRCCourt RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …
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-…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCFinal Rules (FR)Aug 3, 2018
CFR 2590.736, 45 CFR 146.125, and 45 CFR 148.102. Therefore, the Departments proposed conforming amendments to those rules as part of this rulemaking. The Departments also proposed a technical update in 26 CFR 54.9833-1, 29 CFR 2590.736, and 45 CFR 146.125 to delete the reference to the applicability date for amendment…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…