IRCCourt RulingsFeb 9, 2023
…equately respond to c omments. See Chevron, U.S.A.,
Inc. v. Nat . Res. Def. Council, Inc., 467 U.S. 837, 844
(1984); Motor Vehicle Mfrs. Ass’n of the U.S., Inc. v. State
Farm Mut. Auto. Ins. Co. , 463 U.S. 29 (1983); Altera Corp.
& Subs. v. Commissioner , 145 T.C. 91, 120, 130 (2015),
rev’d, 926 F.3d 1061 ( 9th 2019). …
IRCCourt RulingsApr 12, 2011
…e shows how he paid the premium each year:
Year Paid by Check Paid by Loan Paid by Dividend 1982 $1,837 -0- -01983 1,837 -0- -01984 1,837 -0- -01985 1,837 -0- -01986 1,837 -0- -01987 -0- $1,837 -01988 -0- 1,837 -01989 -0- 1,837 -01990 -0- 1,837 -01991 -0- 1,837 -01992 -0- 1,837 -01993 -0- 1,837 -01994 -0- 1,837 -01995 …
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
…lations is well
known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def.
Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v.
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…ital asset must be narrowly applied and its exclusions
interpreted broadly.” Boree v. Commissioner, 837 F.3d 1093, 1100 (1 1th
Cir. 2016) ( quoting Corn Prods. Ref in . Co. v. Commissioner , 350 U.S. 46,
52 (1955)), aff ’ g in part, rev ’ g in part T.C. Memo. 2014-85.
The Eleventh Circuit has explained that this determ…
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 RulingsJan 30, 2007
…me tax of $314,372 and an addition
SERVED JAN 3 0 2007
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to tax under section 6651(a)(1) of $38,837.¹ After concessions,2
the issues for decision are: (1) Whether respondent's and
petitioners' motions to conform pleadings to the evidence should
be granted; (2) whether petitioners received but failed to report
certa…
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 RulingsApr 2, 2024
…ey are entitled to deference under Chevron, U.S.A.,
Inc. v. Nat. Res. Def. Council, Inc. , 467 U.S. 837 (1984), and
that the P etition was untimely filed under their provisions.
Ps agree that Chevron provides the proper framework for
the Court to review the regulations and that the deadline
to file their P etition was …
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 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…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022
…ts per plan, this results in the distribution of approximately 2,297 SPEs, of which approximately 1,837 (80 percent) will be mailed. The material cost associated with mailing the 1,837 SPEs at $.05 per page is approximately $92. Therefore, the total cost burden for distribution of the notices and SPEs is estimated to b…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…ot complete at the time of the study, this figure represented a 10 percent increase from 2021, when 837 shareholder proposals were submitted. There was a similar 11 percent increase between 2020 and 2021, when the number of proposals increased from 754 to 837. Based on projections for the rest of the year, the authors …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…ces × 1 hour × $113.77 = $13,712,123. Therefore, the total burden hours are 301,312 + 120,525 = 421,837 and the total equivalent costs are $36,925,829 + $13,712,123 = $50,637,952. The printing and material costs are $12,052. Therefore, $50,637,952 + $12,052 = $50,650,005.
Back to Citation
280.
301,312 + 120,525 = 421,…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
IRCFinal Rules (FR)Nov 12, 2020
…(i); 2590.715-2715A2(b)(2)(i); and 147.211(b)(2)(i)
0938-1372*
1,959
1,959
23,313
45,670,820
$6,388,837,830.32
$0
$6,388,837,830.32
§§ 54.9815-2715A2(b)(2)(ii); 2590.715-2715A2(b)(2)(ii); and 147.211(b)(2)(ii)
0938-1372
1,306
84,926
11
21,231
849,256.00
39,065.78
888,321.78
§§ 54.9815-2715A3(b)(i); 2590.715-2715A3(b)(i…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…h annuity payable to the spouse for the spouse’s life beginning upon the participant’s death was $7,837 (calculated using the applicable interest rate and applicable mortality table under § 417(e)(3)), the single-sum payment to the spouse under clause (iii) of this section .07(2) is equal to $7,837. If the single-sum p…
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…
IRCCourt RulingsJan 14, 2013
…10,562
1993 41,365 25 10,132
1992 39,908 25 9,179
1991 38,502 25 9,323
1990 37,146 25 8,943
1989 35,837 25 8,579
1988 34,575 25 8,229
1987 33,357 25 7,894
1986 32,182 25 7,572
1985 31,048 25 7,264
1984 29,955 25 6,968
1983 28,899 25 6,684
1982 27,881 25 6,412
- 17 -
[*17] 1981 26,899 25 6,151
1980 25,952 25 5,900
1979 …