IRCCourt RulingsSep 26, 1968
Simpson, Judge:
The respondent determined deficiencies in the income tax of the petitioners of $1,523.06 for the taxable year 1961 and $5,045.75 for the taxable year 1962. The only issue remaining for decision is whether a distribution received by the petitioner Maurice Osterman in 1962 from an exempt employees’ pensio…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
.1763434
4,826,970
$504,465,709
$784,429
2023
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
735,318
2024
4,059,610
4,103,368
1.1763434
4,826,970 504,465,709
735,318
3 Year Average
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
751,688
Table 52—DOL's and Department of the Treasury's Summary Table
Year
Estimat…
IRCCourt RulingsMar 16, 2006
…isability, entitling her to disability annuity
payments as of July 1, 1998.
Petitioner received $14,970.84 in annuity payments from the
RRB during the 2001 taxable year. For that year, petitioner
-3received a Form RRB-1099-R, Annuities or Pensions by the Railroad
Retirement Board. Listed on the Form RRB-1099-R are the
…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
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 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 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 RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
IRCCourt RulingsMar 31, 2005
…r failed to report the $11,567
distribution from Standard Insurance Company, and the additional $46,970 distribution from New York Life from Mr. Seidel’s CWSC
- 9 -
3
The amount of $5,442 which was disallowed by respondent is
actually the total net loss reported on Schedule C from
petitioner’s activity, Port of Mystery…
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 RulingsJul 24, 1991★ strong match
ding $52,970. Petitioner deposited the check in his personal bank account. Sometime later, on two separate occasions, petitioner sold the Sears stock. On February 1, 1983, petitioner drew a check on his personal account in the amount of $52,970, payable to Yolanda. In the “Memo” section of the check he wrote “Property …
IRCCourt RulingsApr 19, 2005
… deficiency mailed to Ms. Seidel respondent determined that she failed to
report the additional $46,970 distribution from New York Life
from petitioner’s CWSC 401(k) plan.
- 8 -
Although Ms. Seidel reported one-half of the net
distribution of $60,060, or $30,030 in gross income on her 1999
Federal income tax return, sh…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…den hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Financial Adviser
622,676
$141,970,058
622,676
$141,970,058
Total
622,676
141,970,058
622,676
141,970,058
These rollover disclosures
are expected to be two pages in length and accompany other documentation associated with the transactions at no additi…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…ofit institutions.
Respondents:
2,588,983.
Responses:
33,829,725.
Estimated Total Burden Hours:
303,970.
Estimated Total Costs:
$15,224,218.
Description:
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…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023
…ceipt of such cash under section 6050I and these regulations.
(ii)
Casinos exempt under 31 CFR 1010.970(c).
Under the authority of section 6050I(c)(1)(A), the Secretary may exempt from the reporting requirements of section 6050I casinos with gross annual gaming revenue in excess of $1,000,000 that are exempt under 31 C…
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
ERISACourt RulingsAug 25, 1995
…es. John Hancock Mutual
Life Ins. Co. v. Harris Trust and Savings Bank, 14 S.Ct. 517
(1993), citing 970 F.2d 1138 at 1145.
In Hancock there was an existing defined ERISA plan.
At issue was whether certain assets were "plan assets" with
respect to general fiduciary responsibilities. In
Hancock, the Court held that a gro…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021
…ceipt of such cash under section 6050I and these regulations.
(ii) Casinos exempt under 31 CFR 1010.970(c). Under the authority of section 6050I(c)(1)(A), the Secretary may exempt from the reporting requirements of section 6050I casinos with gross annual gaming revenue in excess of $1,000,000 that are exempt under 31 C…