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86 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    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 …
  2. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …itial registration × $77.78 combined average hourly rate = $894.50 cost per respondent. $894.50 × 1,585 respondents = $1,417,783 total one-time cost. 0.75 hours per respondent for annual updates × $74.67 combined average hourly rate = $56 cost per respondent. $56 × 1,585 respondents = $88,760 total annual cost. Back to…
  3. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …e and distribute comparative analyses upon participant request 2,129,516 0.083 177,460 65.99 11,710,585 2.79 2,477,543 Clerical workers maintain recordkeeping 2,129,516 0.083 177,460 65.99 11,710,585 0 0 Total 2,129,536 355,020 23,433,073 2,477,543 1.5. Overall Summary
  4. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    …contribution amount for 3 1/2 months at the effective interest rate ($25,000 ÷ 1.0590(3.5/12) = $24,585).(B) The contribution paid July 15, 2017 is discounted for 6 1/2 months at the effective interest rate ($25,000 ÷ 1.0590(6.5/12) = $24,236).(C) The contribution paid October 15, 2017 is discounted for 9 1/2 months at…
  5. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …ble 9, across all 1,580 issuers and TPAs, the estimated total ongoing burden would be approximately 585,000 hours, with a total annual cost of approximately $23.4 million.
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    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…
  7. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    …- 30 - Dr . Durante 931250795PR 50,000 50,000 Ms . Quinn 931250796PR 12,000 12,00 0 Total ' 587,750 585,00 0 'We recognize that VRD / RTD deducted for 1993 contributions totaling $ 585,000 . In that the premiums paid in 1993 totaled $ 587,750, we are unable to find in the record an explanation as to who paid the extra …
  8. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  9. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …lan paid the first-year premium, and, at the end of that year, the conversion credit balance was $8,585.88 ($9,906 - $1,689.85 + $369.73); the $369.73 is the interest of 4.5 percent earned on the conversion credit balance (($8,585.88 - $369.73) x 4.5% = $369.73)). None of the conversion credit balance could have been -…
  10. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    … canceling notes, and recorded by journal entries. Thus, MPC issued MIT 86 - 79 - 25 The amount of $585,511 appearing on the note was incorrect and should have been $588,511. The transaction was recorded on the books of MIT 86 and MPC in the amount of $588,511. a demand note in the amount of $585,511, 25 without intere…
  11. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    United States Tax Court T.C. Memo. 2022-69 CLAIR R. COUT URIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed July 6, 2022. ————— Alvah Lavar Taylor and Daniel W. Soto , for petitioner. Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and Edward T.…
  12. T.C. Memo. 2015-176 — Ronald Craig Fish v. Commissioner
    IRCCourt RulingsSep 10, 2015
    …, etc., for a partial distribution that he received from his IRA. The Form 1099-R reported that $40,585 had been distributed from the IRA to petitioner in 2009, all of which was
  13. Treas. Reg. § 1.436-1(d)(3)(v) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …0 + .590 × $1,500), and the benefit payable for Participant's lifetime, beginning after age 62, is $585 per month ($2,085−$1,500).(iii) Because the optional form provides some payments which are greater than payments described in paragraph (j)(6)(i)(A) of this section ($1,200), the portion of the benefit that is being …
  14. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  15. 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…
  16. 61 T.C. 605; 61 T.C. No. 65 — Estate of Silverman v. Commissioner
    IRCCourt RulingsFeb 4, 1974★ strong match
    be communicated to Participant by the Committee to the Trustee, and the Trustee upon receipt thereof, shall adopt such selection and comply therewith. 3. If the employment of any Participant is terminated and Participant is reemployed by the Corporation or the Subsidiary, he shall be deemed under all provisions of this…
  17. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  18. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    t to "a former spouse * * * who is recognized by a domestic relations order as having a right to receive" a share of the proceeds. See sec. 414(p)(8). Second, the distribution was not made "pursuant to a qualified domestic relations order." Although Jeremy's petition for dissolution of marriage requested a 50-50 divisi…
  19. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  20. 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
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…