T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…rtion average 8.7 acres in gross area with an average building pad of
approximately 1.02 acres (4 3,996 sf).
32
Th ese lots are generally larger
than the lots emphasized by petitioner’s experts and smaller than
several lots emphasized by respondent’s expert. N one of the appraisal
experts provided consistent quantitati…
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 RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJan 14, 2013
…8 24,155 -0- 24,155 5,429 -0- 5,429
1977 23,304 -0- 23,304 5,208 -0- 5,208
1976 22,484 -0- 22,484 4,996 -0- 4,996
1975 21,691 -0- 21,691 4,792 -0- 4,792
1974 20,927 -0- 20,927 4,597 -0- 4,597
1973 20,190 -0- 20,190 2,205 -0- 2,205
Total 1,068,923 512,985 555,938 558,053 315,699 242,354
For the years for which a "-0-" a…
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 …
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ebcast_pptx.pdf.
Back to Citation
58. The burden is estimated as: [(395 small broker-dealers + (2,996 small registered-investment advisers × 8%) + 151 small insurers + 10 small robo-advisers + 930 small pension consultants + 20 small investment company underwriters) × 10% × 5 hours] + [(1,499 large broker-dealers + (…
IRCCourt RulingsAug 3, 1979related by meaning
istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ns described in Section III(a)-(f) for each plan and IRA. In total, the Department estimates that 2,996 entities would prepare disclosures for plans and 2,996 entities would prepare disclosures for IRAs. The Department assumes that an in-house attorney will spend one hour of legal staff time drafting the disclosure for…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ificantly reduces the risk retained by the plan sponsor.[205]
Applying this percentage to the 2,454,996 small, ERISA-covered group health plans,[206]
the Department estimates there are approximately 1,031,098 level-funded group health plans.[207]
The Department also estimates that there are 104,123 self-insured group h…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…stimated baseline monthly storage cost of roughly $22,583 with an annual cost of approximately $270,996. With a 70 percent reduction in file size, monthly storage costs would decrease to approximately $6,651 ($79,812 annually), yielding a monthly savings of $15,932 and an estimated annual savings of approximately $191,…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
IRCCourt RulingsJun 17, 1997
…in the Prime Plan
listed the following relevant data:
1988
1989
1990
1991
Fund value at yearend $99,996 $138,653 $158,161 $167,047
Policy values 99,996 138,653 157,814 167,055
Surrender value Unstated Unstated 136,959 147,056
Addit. contr. available (11) 2 61,519 128,443
Date of report 03/11/91 03/11/91 07/10/91 01/20/…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…cost
Total estimated
cost
2021
17,467
17,467
59,472
$6,758,568
$2,965
$6,761,533
2022
17,467
50,797,996
0
0
2,539,900
2,539,900
2023
17,467
50,797,996
0
0
2,539,900
2,539,900
3 Year Average
17,467
33,871,153
19,824
2,252,856
1,694,255
3,947,111
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…ses would have been $567,884 for BI's fiscal year 1988,
- 29 -
$888,742 for BI's fiscal year 1989, $996,886.40 for BI's fiscal
year 1990, and $287,010 for BI's fiscal year 1991. This
computation is as follows:
Income before 8-percent of 8-percent of
taxes of GSI income before income before
FY ended
& subsidiaries
taxes…
89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption PBGCFinal Rules (FR)Dec 20, 2024
…8468
0.48417
112
0.49268
0.49226 113
0.49666
0.49634
114
0.49795
0.49773
115
0.49928
0.49915
116
0.49960
0.49953
117
0.49978
0.49973
118
0.49995
0.49993
119
0.50000
0.50000
120
1.00000
1.00000
( printed page 104043)
3. Amend § 4044.58 by revising table 1 to § 4044.58 to read as follows:
§ 4044.58
Tables used to determi…
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 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…
IRCCourt RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
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 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…