IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsJul 8, 2020
…ouse $19,092 during 2016, consisting of $9,283 distributed to Morehouse from her 529 account and $9,809 in
payments separately documented by her bank statements. We find that $5,816 of
the latter sum represented the balance of her withdrawals from the section 529
account (viz., the portion distributed to her rather tha…
PLR 201128017 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 15, 2011
…Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494 (1984), the controlling provision
was § 809(c)(1). Thi s provision was interpreted by § 1.809-4(a)(1)(i), which provided
that
The term “gross amount of all premiums” means the
premiums and other consideration provided in the insurance
or annuity contract. Thus…
PLR 201105005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsFeb 4, 2011
…fer of property in an assumption
reinsu rance transaction as defined in paragraph (a)(7)(ii) of § 1.809-5). The term also includes amounts a life insurance
company charges itself representing premiums with respect
to liability for insurance and annuity benefits for its
employees (including full-time life insurance sale…
IRCCourt RulingsJul 6, 2010
…petitioner received distributions totaling'$60,937 as follows :
$24,689 from account No . 8052, $18,809 from account No . 9853,6
and $17,439 from account No . 9052 .' In 2006 petitioner was not
yet 59-1/2 years old .
Petitioner filed her 2006 Form 1040 ., U .S . Individual Income
Tax' Return, -electronically ."' Petiti…
IRCCourt RulingsAug 6, 1996★ strong match
by section 404(a)(6), and are therefore not deductible
in that year.
To reflect the foregoing and issues previously resolved,
Decision will be entered under Rule 155
.
IRCCourt RulingsMay 25, 2005★ strong match
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
IRCCourt RulingsMar 31, 1997related by meaning
ons of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
- 3 - After concessions, the following 2 issues remain for us to
resolve in the present proceeding: (1) Whether petitioner, in
its taxable year ending January 30, 1988 (TYE 88…
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 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 RulingsMar 10, 2020
…ation for the statutory distinction. McDonald v. Board of
Election Com'rs of Chicago, 394 U.S. 802, 809 (1969).
Estate of Kunze v. Commissioner, 233 F.3d 948, 954 (7th Cir. 2000), § T.C.
Memo. 1999-344.5
This Court follows the same framework in evaluating equal protection
claims regarding statutes affecting economic ri…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…0-0040.
Affected Public:
Businesses or other for-profits, Not-for-profit institutions.
Respondents:
809,901.
Responses:
178,211,549.
Estimated Total Burden Hours:
1,068,322.
Estimated Total Costs:
$18,423,119.
Descriptions:
IRCCourt RulingsJul 23, 1981
…aph (B)).” Sec. 2(3), Self-Employed Individuals Tax Retirement Act of 1962, Pub. L. 87-792,76 Stat. 809,811. For an explanation of the effect of sec. 911(b) on "earned income” under present law as compared with prior law (prior to sec. 204(c), Foreign Investors Tax Act of 1966, Pub. L. 89-809,80 Stat. 1539,1577, effect…
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…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…e will affect 205 TPAs and 373 issuers (
i.e.,
health insurance companies) in the group market with 809 issuers/State combinations [211]
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAProposed Rules (FR)Proposed Oct 14, 2021
…ct and Indirect
941
586
1,527
1
1,528
Total
5,005
20,463
25,468
573
26,041
ESOP (No Common Stock)
5,809
5,809
5,809
Common Stock and ESOP
591
591
591
Total All Plans Holding Stocks
5,005
26,863
31,868
573
32,441
a
DOL calculations from the 2018 Form 5500 Pension Research Files.
There are approximately 629,000 small pe…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…ct and Indirect
849
645
1,494
1
1,495
Total
4,558
19,564
24,122
518
24,640
ESOP (No Common Stock)
5,809
5,809
5,809
Common Stock and ESOP
574
574
574
Total All Plans Holding Stocks
4,558
25,947
30,505
518
31,023
a
DOL calculations from the 2020 Form 5500 Pension Research Files.
There are approximately 652,900 small pe…