IRCCourt RulingsJul 14, 2005★ strong match
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019
…9
$9,472.
§ 1903.15(d)(1) $129,336
$132,598.
§ 1903.15(d)(2)
$129,336
$132,598.
§ 1903.15(d)(3)
$12,934
$13,260.
§ 1903.15(d)(4)
$12,934
$13,260.
§ 1903.15(d)(5)
$12,934
$13,260.
§ 1903.15(d)(6)
$12,934
$13,260.
DEPARTMENT OF LABOR
Mine Safety and Health Administration
Title 30—Mineral Resources
PART 100—CRITERIA AND P…
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 RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
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 RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont… IRCTreasury DecisionsSep 28, 2015
…erest rate ($200,000 ÷ 1.0590(6/12) = $194,349), for a total interest-adjusted contribution of $201,934.
(iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bal…
IRCCourt RulingsJul 13, 2015
…ravel
expenses $14,043
Taxes 8,891
Gambling losses--
other miscellaneous
deductions 25,000
Total 47,934
- 6 -
[*6] On the Form 1040X petitioner claimed that he was a professional gambler
with the following Schedule C income and expenses:
Schedule C Amount claimed
Income:
Gross receipts $25,000
Returns 25,000
Gross inco…
IRCRegulationsSep 9, 2016
…erest rate ($200,000 ÷ 1.0590(6/12) = $194,349), for a total interest-adjusted contribution of $201,934.(iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bala…
80 FR 54374 — Determination of Minimum Required Pension Contributions IRCFinal Rules (FR)Sep 9, 2015
…erest rate ($200,000 ÷ 1.0590(6/12)
= $194,349), for a total interest-adjusted contribution of $201,934.
(iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bal…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
Notice 2016-39 — This notice provides guidance as to whether payments received by an employee from a qualified defined benefit plan during phased retirement are amounts receive… IRCNoticesJun 27, 2016
…ring that period. At the annuity starting date, Employee M has an investment in the contract of $50,934.19 ($50,000 plus $5,000 in additional contributions minus $4,065.81 in recovered basis). Because Employee M is receiving a joint and survivor annuity, the number of anticipated payments is determined under the table …
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
…s part of the Essential Health Benefits requirements. The Departments estimate that there are 2,134,934 ERISA-covered group health plans with less than 50 participants based on data from the 2021 MEPS-IC and the 2019 County Business Patterns from the Census Bureau. The Departments also estimate that 83 percent of group…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsJan 5, 2017
…T.C. 1, 12 (1989), af[d, 925 F.2d
348, 353 (9th Cir. 1991); see also Neely v. Commissioner, 85 T.C. 934, 947
- 14 -
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsSep 17, 2026
…gible property .” Amazon.com, Inc. & Subs. v.
Commissioner, 148 T.C. 108, 150 – 51 (2017) , aff’d , 934 F .3d 976 (9th Cir. 2019) . “ When
one participant . . . makes pre-existing intangible property available for purposes of
research under a QCSA, that party is deemed to have transferred an interest in such
property t…
IRCRegulationsSep 17, 2024
…balance afterwithdrawal 2028 $1,000,000 $550,000 2029 1 954,545 2 $561,000 3 $555,500 4 $26,606 534,934 2030 909,306 545,633 540,283 26,482 519,151 2031 864,291 529,534 524,342 26,760 502,774 2032 819,740 512,829 507,801 27,177 485,652 2033 775,430 495,365 490,509 27,438 467,927 2034 731,620 477,286 472,606 27,853 449,…