IRCCourt RulingsMar 31, 1961
…h amount is less than 5 percent of petitioner’s actual sales of television bulbs for 1949 of $8,174,895.13. Therefore, it is the contention of Kimble Glass that it satisfies the test set forth in clause (iii) of section 435(e)(1)(B).
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…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…ion of Notices (Hour Burden)
43,172
0
14,391
Printing Costs (Cost Burden)
$13,626,966
$6,530,171
$8,895,769
( printed page 46624)
Agency:
Employee Benefits Security Administration.
Title:
Electronic Disclosure by Group Health Plans Under ERISA.
Type of Review:
New.
OMB Control Number:
1210-NEW.
Affected Public:
Individ…
IRCCourt RulingsJan 14, 2013★ strong match
…097 54,223 19,669 34,554
1999 51,296 26,112 25,184 52,014 3,112 48,902
1998 49,489 26,500 22,989 49,895 -0- 49,895
1997 47,746 26,500 21,246 47,862 -0- 47,862
1996 46,064 26,500 19,564 45,912 -0- 45,912
1995 44,441 25,885 18,556 44,042 -0- 44,042
1994 42,876 23,331 19,545 10,562 -0- 10,562
1993 41,365 20,800 20,565 10,…
IRCCourt RulingsDec 30, 1998
…e Co. (Great-West). GreatWest mailed to petitioner and to respondent a Form 1099-R
indicating that $895 of the $5,149 distribution represented
taxable income to petitioner.
1994 Tax Return and Respondent's Audit
On her 1994 Federal income tax return, petitioner did not
report any taxable income relating to the transfer…
IRCCourt RulingsJul 31, 2000★ strong match
…come $2,303,425 $403,869 $2,411,265 $2,286,460
Officers’ compensation 987,554 350,000 1,171,931 940,895
Salaries & wages 148,750 29,167 200,565 303,750
Pension, profit-sharing, plans 46,907 25,000 132,428 169,170
Employee benefit programs -0- -0- -0- -0-
Other deductions (VEBA contribution) 480,901 -0- 209,869 296,056
…
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 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 24, 1980
…00
1969. 20,399
1970 . 27,988
1971. 63,549
1972. 1,800,274
1973 . 313,863
1974 . 470,495
1975 . 544,895
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…
ERISACourt RulingsAug 17, 2026
… instead . See id. at 1178; s ee also GIW Indus., Inc. v. Trevor,
Stewart, Burton & Jacobsen, Inc., 895 F.2d 729, 733 (11th Cir. 1990).
When assessing this kind of comparator evidence, we have explained that “ whether an investment is objectively imprudent must
be assessed against the actions of a hypothetical prudent …
IRCCourt RulingsMar 1, 1999related by meaning
me-generating activities
relating to the items of income, he has satisfied that obligation
through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation
should have been divided between himself and his spouse, there is
no basis for making any apportionment. …
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…the following calculation: 6,532 claims × 2 hours × $105.01 + 6,532 claims × 0.5 hour × $55.23 = $1,895,077. 2 × $1,895,077 = $3,790,154. Labor rates are EBSA estimates.
Back to Citation
202.
Kaiser Family Foundation. “Surprise Medical Bills: New Protections for Consumers Take Effect in 2022.” (2019).
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…et does not exist typically for conservation
easements. See Symington v. Commissioner, 87 T.C. 892, 895 (1986).
C ourts usually value easements indirectly using a “before and after”
approach, seeking to determine the reduction in property value
attributable to the easement. See Treas. Reg. § 1.170A - 14(h)(3)(i ) .
Und…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCRegulationsJul 26, 2016
…the contract adjusted for the present value of the refund feature without discount for interest $17,895 Example 3.Assume the same facts as in example (1), except that the pre-July 1986 investment in the contract is $10,000 and the post-June 1986 investment in the contract is $11,053. If the annuitant makes the election…
IRCCourt RulingsJun 17, 1997
…ax returns. These returns included the following data:
1988
1989
1990
1991
1992
Total income $1,130,895 $1,108,792 $923,488 $114,270 $603,522
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…9
10
Total
Materials and Postage
$2
$3
$9
$14
$16
$19 $21
$22
$24
$23
$154
Labor Costs
6,206
88
572
895
1,041
1,226
1,415
1,483
1,580
1,547
16,052
Total All Cost
6,208
90
581
909
1,057
1,245
1,436
1,505
1,604
1,570
16,206
Present Value of Total Cost:
3 Percent
6,027
85
532
808
912
1,042
1,168
1,188
1,229
1,168
14,160
7…