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1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   owing differences: I --between the amounts of royalties and other expenses referred to in article 74 of the mentioned Law, credited or paid during the base-year, and the minimum percentages established for the respective deduction, according to (b) and (d); II--between the quotas for the purpose of forming depreciation…
3. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
   IRCCourt RulingsJan 30, 1958related by meaning
   cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
4. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
   IRCCourt RulingsJul 31, 2000
   …1. Dr. Mall’s Inter-American C-Group Term Policy Effective March 15, 1991, Inter-American issued a $650,000 C-group term policy (certificate No. 5076202) on the life of Dr. Mall, age 45. The first-year premium was $9,906, and the cost of insuring Dr. Mall for that year was $1,689.85. The Neonatology Plan paid the first…
5. 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…
6. T.C. Summary Opinion 2016-64 — Rosella Marie Hill v. Commissioner
   IRCCourt RulingsSep 29, 2016
   …led her car. In order to make her mortgage payments and purchase a new car, petitioner withdrew $39,650 from her Citibank retirement account in 2012. Petitioner claims she used the $39,650 distribution as follows: $17,000 to purchase a new car, $10,000 to pay her mortgage, and the rest to pay other bills. On her joint …
7. 72 T.C. 377 — La Mastro v. Commissioner
   IRCCourt RulingsMay 23, 1979related by meaning
   ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
8. 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 …
9. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
   IRCCourt RulingsApr 25, 2011
   ent determined. In the - alternative, petitioner argues that even if she received $22,650 from OPM in 2005,. she is not liable for any.increase in tax because OPM withheld Federal income tax from her payments. As we interpret petitioner's argument, petitioner is contending that OPM withheld insufficient Federal income …
10. 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…
11. Treas. Reg. § 1.401(l)-3(e)(3) — Permitted disparity for defined benefit plans.
    IRCRegulationsMay 18, 2016
    … allowance and maximum offset allowance (percent) 70 1.002 69 0.908 68 0.825 67 0.750 66 0.700 65 0.650 64 0.600 63 0.550 62 0.500 61 0.475 60 0.450 59 0.425 58 0.400 57 0.375 56 0.344 55 0.316 Table II[Social security retirement age 66] Age at which benefits commence Annual factor in maximum excess allowance and maxim…
12. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … the information in the provider's website. This results in an equivalent cost of approximately $50,650,005 to be incurred as a one-time cost in 2021.[279] ( printed page 56080) HHS assumes that each the wholly physician-owned private practice will incur a printing cost of $0.05 per page and materials for a total equiv…
13. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012
    …ersonal property valued at $5,000. Petitioners also reported owning a single family home valued at $650,000 (subject to one or more mortgages totaling $889,805), zero equity, and a monthly mortgage payment of $5,862. According to the Form 433-A, petitioners' home was the subject of a foreclosure proceeding. Petitioners…
14. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
15. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    …00 people per year.[57] The elimination of lifetime limits would extend coverage to an estimated 18,650 to 20,400 people who would be expected to exceed a lifetime limit during a calendar year. Table 3.4—Percent and Number of Persons Expected To Exceed a Lifetime or Annual Limit   Projected to ever exceed limit Percent…
16. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
17. T.C. Summary Opinion 2020-6 — Jemar Y. Purdie v. Commissioner
    IRCCourt RulingsJan 21, 2020
    …ion shall not be treated as precedent for any other case. Respondent determined a deficiency of $14,650 in petitioner's Federal income tax and an accuracy-related penalty of $2,875 under section 6662(a) for 2016. The issue before this Court is whether to grant respondent's motion for summary judgment (motion) pursuant …
18. Treas. Reg. § 1.72-4(ii)(2) — Exclusion ratio.
    IRCRegulationsJul 26, 2016
    …A purchased an annuity contract providing for payments of $100 per month for a consideration of $12,650. Assuming that the expected return under this contract is $16,000 the exclusion ratio to be used by A is $12,650 ÷ 16,000; or 79.1 percent (79.06 rounded to the nearest tenth). If 12 such monthly payments are receive…
19. T.C. Summary Opinion 2018-16 — Albert Anthony Oliver v. Commissioner
    IRCCourt RulingsApr 3, 2018
    …040, U.S. Individual Income Tax Return, petitioner reported taxable retirement distributions of $37,650, comprising $17,000 from OneWest Bank and $20,650 from CalPERS. In the notice of deficiency respondent determined that petitioner should have reported $44,850 of taxable retirement distributions, reflecting an additi…
20. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971related by meaning
    n will be entered under Rule 50. Drennen, /., dissents. All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…