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…
IRCCourt RulingsJul 14, 2005related by meaning
that the Court vacate its Order [sic] of
August 16 and order the parties to submit computations
pursuant to Rule 155. This will permit the parties the opportunity to determine whether TLC's liability should
be reduced by the amounts already paid by parties to
the transaction.
On the record before us, we reject petition…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
… $62,860,146 $83,594,015
Retired employees 26,311,902
36,694,928
47,731,960
48,947,859
Total 39,673,488 75,216,785 110,592,106 132,541,874
2. Actuarial value of assets
VEBA -0- 30,736,554 30,176,217 39,940,676
IRCCourt RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ctivity
Burden hours
Equivalent
burden cost
Burden hours Equivalent
burden cost
Legal
10,352
$1,649,488
0
$0
Total
10,352
1,649,488
0
0
For the added requirement of a written statement informing the investor of their right to obtain a written description of the financial institution's policies and procedures and inform…
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…
ERISAProposed Rules (FR)Proposed Jul 21, 2016
… total burden associated with the Form 5500 Annual Return/Report has risen from $327.98 million to $488.1 million since the last rulemaking in November 2007 primarily due to the increase in wage rates and the number of plan filers over the last eight years under the current rule. In other words, approximately 90 percen…
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
… and $1.14 in postage for a 3-ounce parcel. Therefore, the cost burden is calculated as follows: (1,488,476 fully-insured, non-grandfathered plans with less than 50 participants + 409,822 ERISA-covered group health plans with 50 or more participants) × 41.8% × ($1.14 + (15 pages × $0.05)) = $1,499,693.
Back to Citation…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…uring
CEO 1989 162.416 343.92 522.82 701.72
Non-Durable Goods Manufacturing
CEO 1989 162.416 351.03 488.82 626.61
All Non-Manufacturing
CEO 1989 162.416 343.83 488.25 632.67
Wholesale Trade
CEO 1989 162.416 380.49 580.02 779.55
Services
CEO 1989 162.416 362.71 508.11 653.51
Business Services
CEO 1989 162.416 359.46 497…
IRCCourt RulingsJun 17, 1997
…turns included the following data:
1988
1989
1990
1991
1992
Total income $1,130,895 $1,108,792 $923,488 $114,270 $603,522
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… + 1,011 pension consultants, and 20 investment company underwriters) × 1 hour]} × $159.34 = $1,649,488.
Back to Citation
476. The burden is estimated as: [(1,894 broker-dealers + 15,982 registered investment advisers) × (30 minutes ÷ 60 minutes)] + [(183 insurers + 200 robo-advisers + 1,011 pension consultants, and 2…
IRCCourt RulingsDec 11, 2003related by meaning
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…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
….03.Substantial completion of correction . . .. . .. . .. . .. . .. . .. . .. . ................... 488
.04 Examples ........................................................................................ 488
PART V. VOLUNTARY CORRECTION PROGRAM WITH IRS APPROVAL (VCP)
SECTION 10. VCP PROCEDURES
.01 VCP requirements .…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsMar 7, 2019
…ified
Schedule C Gross plan Taxable
Yeg Wages income income deduction income
2004 $21,500 $275,000 $488,732 $275,000 $102,482
2005 19,925 167,964 254,704 167,964 32,515
2006 19,268 201,192 427,696 201,192 107,468
2007 19,253 221,664 422,716 221,664 91,573
And here's the big picture of BAI's original corporate returns f…
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…
IRCCourt RulingsFeb 6, 1992★ strong match
… 528, 536 (1978); see also National Muffler Dealers Association, Inc. v. United States, 440 U.S. at 488. The Supreme Court also indicated in National Muffler Dealers Association, Inc., 440 U.S. at 488, that a taxpayer “needs more than a plausible policy argument to prevail * * *. * * * The choice among reasonable inter…
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 RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…