143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner IRCCourt RulingsAug 26, 2014
… to the Internal Revenue Service on a 2009 Form 1099-MISC,
Miscellaneous Income, "Other income" of $668. Petitioners did not report the income shown on the 2009 Form 1099-MISC on the Form 1040. At trial, in order
to show that the 2009 Form 1099-MISC properly and accurately reported the
income shown thereon, respondent …
IRCCourt RulingsDec 23, 1996related by meaning
tz v. Commissioner
,
supra
, and Kasey v. Commissioner
, supra
, is also misplaced. In
those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and
remitted to judgment creditors. In neither case is there any
indication that the taxpayers disputed their …
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…ernet Availability (First year)
21,586
0.25
193.15
1,042,334
−3,127,002
21,586
0.5
193.15
2,084,668
−2,084,668 Primary Assumption
21,586
1
193.15
4,169,336
0
21,586
2
193.15
8,338,672
4,169,336
21,586
3
193.15
12,508,008
8,338,672
3. Initial Notice of Default E-Delivery and Right to Opt Out:
A. Compensation and…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
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 RulingsOct 9, 1997related by meaning
nd contribution, made
during December 1986, would be deductible in 1986, because that
contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986.
Accordingly, petitioner argues, the regulation contradicts the
plain language of section 419 and is invalid. Petiti…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…e
Property. He concluded that there was significant excess (net) demand in 2017– 18 averaging 3,976,668 tons per year that a quarry at the
Property would be competitively positioned to serve.
2. John Joseph Howle
Joseph Howle had a 38-year career in environmental compliance,
including 29-plus years with Vulcan. We reco…
IRCCourt RulingsOct 10, 1979related by meaning
es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
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 RulingsDec 11, 2003★ strong match
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsJan 14, 2013
…s. The Fletchers concede that they are also not
entitled to deduct other Schedule E taxes of $709, $668, and $1,916 for the 2003,
2004, and 2005, tax years, respectively, and respondent concedes that they are.
entitled to deduct those expenses oil Schedule A. The Fletchers concede that they
are not entitled to deduct S…
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…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…17 2,170,000 13,966,816 12,247,933
N. Value of assets (yearend) 30,736,554 30,176,217 39,940,676 47,668,557
O. Nondeductible contribution
carryforward
6
22,034,781 14,394,743 14,426,384 11,507,465
P. Deductible limit
7
8,654,936 9,810,038 13,935,175 15,166,852
1
C.c - D
2
B.c - E
3
F/G
4
A x (C.a - D + H + ½ of (J - I)…
IRCCourt RulingsAug 15, 1994
…ptember 1, 1988 (photocopy enclosed). I was also advised that the maximum contribution could be $58,668.00. Certainly you should be able to re-calculate from the maximum contribution of $58,668.00 a slightly lower amount which should approach $56,773.00 in view of the lower assets of approximately $11,000.00 which the …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…care facilities × 2 hours × $140.96 = $69,165,125. 245,336 health care facilities × 0.5 hours = 122,668 hours. A labor rate of $46.07 is used for a medical secretary and administrative assistant. The labor rate is applied in the following calculation: 245,336 health care facilities × 0.5 hours × $46.07 = $5,651,315. 24…
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…
75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2010
…614
614
2,598
2,598
2017
627
627
2,652
2,652
2018
640
640
2,708
2,708
2019
654
654
2,765
2,765
2020
668
668
2,823
2,823
2021 or later
682
682
2,882
2,882
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington, DC, this 29th day of November 2010.
Vincent K. Snowbarger,
Deputy Director for Operations…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…ed page 32222)
performance during the 2020 financial crisis caused by the COVID-19 global pandemic.[668]
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 RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …