IRCCourt RulingsJul 5, 2011
… est. Swanson v. Commissioner, T-.C. Memo. 200931 (citing LaVerne v. Commissioner, 94 T.C. 637, 652-653 -(1990),
affd. without pu lished opinion 956 F.2d 274 (9th Cir. 1992));
see Hansen v. Commissioner, 471 F.3d 1021, 1031 (9th Cir. 2006),
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…rial value of assets
VEBA -0- 30,736,554 30,176,217 39,940,676 401(h) -0-
1,125,467
1,172,269
7,598,653
Total -0- 31,862,021 31,348,486 47,539,329
3. Actuarial present value of
future normal costs [1-2]
1
13,361,588 43,354,764 79,243,620 85,002,545
4. Actuarial present value of
future service 4.81 6.63 7.26 7.19
5. Nor…
IRCCourt RulingsJul 31, 2000
…rm policy (certificate No. 6007725) on the life of Dr.
Mall, age 46. The first-year premium was $10,653.50, and the
cost of insuring Dr. Mall for that year was $1,764.60. The
Neonatology Plan paid the first-year premium, and, at the end of
that year, the conversion credit balance was $9,288.90
($10,653.50 - $1,764.60 +…
IRCCourt RulingsJun 17, 1997
…ime Plan
listed the following relevant data:
1988
1989
1990
1991
Fund value at yearend $99,996 $138,653 $158,161 $167,047
Policy values 99,996 138,653 157,814 167,055
Surrender value Unstated Unstated 136,959 147,056
Addit. contr. available (11) 2 61,519 128,443
Date of report 03/11/91 03/11/91 07/10/91 01/20/93
1992
1…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsMar 31, 2015related by meaning
Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the
IRM provision that addresses the Commissioner's ability to levy upon retirement
accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330
hearing request and provided documents supporting this claim. Settlement Officer
Degiovanni …
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 RulingsFeb 22, 1989★ strong match
… board, La.R.S. 42:652 requires that they be credited to the Employees’ Savings Account. La.R.S. 42:653 requires that the employer contributions be credited to the Employer’s Accumulation Account. When the member retires, his or her accumulated contributions are to be credited to the Retiree’s Annuity Reserve pursuant …
IRCCourt RulingsOct 29, 2013related by meaning
ed CST, an entity owned by his IRA, to enter into a lease agreement
with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for
the year in which the prohibited transaction occurred petitioners are liable for the
additio…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…stment. See §§ 6234(a) (BBA § 1 101(c)(1), 129 Stat. at 634),
6226(a) (TEFRA § 402(a), 96 Stat . at 653) ; see also Mammoth Cave , 166
T.C ., slip op. at 10. The replacement of the FPAA with the FPA does not
affect the burden of proof. Accordingly, the adjustments in the FPA are
presumed correct , and petitioner bears …
T.C. Memo. 2017-142 — Block Developers, LLC, William J. Maxam, APC, Tax Matters Partner v. Commissioner IRCCourt RulingsJul 18, 2017
…es:¹4
Additions to tax
Petitioner Excise Tax Sec. 6651(a)(1) Sec. 6651(a)(2)
Mr. Jansson $11,793 $2,653.42 $1,827.91
Mrs. Jansson 11,793 2,653.42 1,827.91
Niklas 11,793 2,653.43 1,827.92
Fred 11,793 2,653.43 1,827.92
We consolidated the cases and tried them in San Diego. Block's principal
place of business was in Calif…
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 7, 1984
…ry Alice Saunders 1978 1,897.00 304.50
William H. Strong and Ella K. Strong 1978 1979 1980 4,558.31 653.10 653.10 653.10
The issues for decision are as follows:
(1) Whether any portion of the terminating distributions from a pension plan received by petitioner-husbands in 1978 may be "rolled over” tax free to individua…
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 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…n:
A. Legal professional reviews proposed rule (First year)
21,586
0.5
$187.58
$2,024,551
−$6,073,653
21,586
1
187.58
4,049,102
−4,049,102
( printed page 46620)
Primary Assumption
21,586
2
187.58
8,098,204
0
21,586
4
187.58
16,196,408
8,098,204
21,586
5
187.58
20,245,509
12,147,306
2. Notice of Internet Availab…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
…2); Jewell v. United States, 548 F.3d 1168, 1172 (8th Cir. 2008); DeNiro v. United States, 561 F.2d 653 (6th Cir. 1977).
IRCCourt RulingsAug 30, 1993related by meaning
ding standard under section 412(d) but chose not to do so. We sustain respondent's determination of petitioner's section 4971(a) excise tax liability. FYE 1987 Employer ReversionSection 4980(a) imposes a 10-percent tax on the amount of any employer reversion from a qualified plan. The term "employer reversion" is defin…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…nancial institutions × 2 hours) + ((1,231− 960 financial institutions) × 4 hours)] × $190.63 = $572,653. Back to Citation
494.
This is estimated as: ($119,505 + $215,428 + $572,653) = $907,586.
Back to Citation
495.
As discussed in the Regulatory Flexibility Act analysis, the Department estimates that 960 entities, c…