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95 documents · 0.39sAllIRCERISAPBGCJoint Board
  1. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    t to which the restrictions apply) has exhausted all remedies prescribed by foreign law or practice for obtaining a waiver of such restrictions (other than remedies that would have a negligible prospect of success if pursued); (C) The restrictions expressly prevented the payment or receipt, i n any form, of part or all…
  3. Treas. Reg. § 54.9815-1251(g)(5) — Preservation of right to maintain existing coverage.
    IRCRegulationsJan 14, 2021
    …al inflation (as defined in paragraph (g)(4)(i) of this section) from March 2010 is 0.2269 (475−387.142 = 87.858; 87.858 ÷ 387.142 = 0.2269). The maximum percentage increase permitted is 37.69% (0.2269 = 22.69%; 22.69% + 15% = 37.69%). Because 33.33% does not exceed 37.69%, the change in the copayment requirement at th…
  4. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    ra . On the other hand, in Larotonda v. Commissioner , 89 T.C. at 292, we recognized the same legislative purpose in respect of the addition to tax on distributions from Keogh plans under section 72(m)(5), but held that that section did not apply where the proceeds of such a plan were levied upon to satisfy respondent'…
  5. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010★ strong match
    …rrect, and the taxpayer bears the burden of proving that the determination . is in error . See Rule 142(a) ; Welch v . Helvering , 290 U .S . 111, 115 (1933) . Pursuant to section 7491(a), the burden of proof as to factual matters shifts .to the Commissioner under certain circumstances . Petitioners have neither allege…
  6. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  7. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005
    …s. On their joint Federal income tax return for 2000, petitioners reported as gross income the $115,142.97 in distributions from their qualified plans. Petitioners included with their 2000 tax return Form 5329, Additional Taxes Attributable to IRAs, Other Qualified Retirement Plans, Annuities, Modified Endowment Contra…
  8. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015
    …3001(c), 112 Stat. at 727, and the taxpayer in that case anyway bore the burden of proof under Rule 142(a), see Matthews v. Commissioner, 92 T.C. at 361-362 (citing Rule 142(a), and Welch v. Helvering, 290 U.S. 111, 115 (1933)). Moreover, none of the recent cases that relied on Bunney cited or discussed the applicabili…
  9. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    Commissioner, 142 S. Ct. at 1501. In doing so, the Sup reme Court rejected the Commissioner’s argument that the express jurisdictional text of section 6330(e)(1) suggested that the deadline under section 6330(d)(1) was also jurisdictional. Boechler, P.C. v. Commissioner, 142 S. Ct. at 1499– 500. The Supreme Court state…
  10. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    itle (other than this subsection) applies with respect to such amount. The pertinent portion of sec. 1.72-2(a)(3)(i), Income Tax Regs., is as follows: Sections 402 and 403 provide that certain distributions by employees’ trusts and certain payments under employee plans are taxable under section 72. * * * For purposes o…
  11. T.C. Summary Opinion 2014-50 — Joel G. Nganga v. Commissioner
    IRCCourt RulingsJun 4, 2014
    rect, and the taxpayer bears the burden of showing that those determinations are erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). 5 At no time since calendar call has the Court heard from petitioner. _ 9 _ Pursuant to section 7491(a)(1), the burden of proof as to factual matters may shift from the …
  12. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  13. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …that a PCT Payment falling within Dr. Newlon’s range is reasonable and chose the midpoint . 51 Rule 142(a) , shifting the burden of proof to respondent. We then discuss the extent to which we will consider posttransaction evidence. Finally, we address the scope and standard of review under section 482. I. Burden of pro…
  14. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …hours. Applying a labor rate for an Independent Producer results in: (4,278 hours × $165.29) ≉ $707,142. For insurers: 358 insurers × 73.1% proportion of entities that are small × 1 hour ≉ 261 hours. Applying a labor rate for a legal professional results in: (261 hours × $165.71) ≉ $43,303. Combining the costs for both…
  15. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  16. 86 FR 51488 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Sep 15, 2021
    … the IRS and the DOL.   DOL IRS Hours Costs Hours Costs Pension: Large Plans 261,464 $62,431,639.11 142,897 $31,568,313.36 Small Plans 174,999 87,694,622.39 176,481 103,113,327.32 Welfare: Large Plans 108,142 111,593,190.83 9,953 1,811,627.38 Small Plans 6,137 5,407,649.86 2,507 1,252,295.71 Total: Large Plans 369,607 …
  17. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  18. Rev. Rul. 2021-3 — Section 401. —Qualified Pension, Profit-Sharing, and Stock Bonus Plans
    IRCRevenue RulingsFeb 1, 2021
    …1981 2048 139,380 1982 2049 140,124 1983 2050 140,820 1984 2051 141,504 1985 2052 141,960 1986 2053 142,368 1987 2054 142,644 1988 and Later 2055 and Later 142,800 ATTACHMENT II 2021 ROUNDED COVERED COMPENSATION TABLE CALENDAR YEAR OF BIRTH 2021 COVERED COMPENSATION ROUNDED 1937 $ 39,000 1938 – 1939 45,000 1940 48,000 …
  19. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
  20. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…