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79 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …Plans with more than 500 participants that will conduct the comparative analysis themselves 709 253 962 Plans with more than 500 participants that will receive generic comparative analyses from TPAs or service providers and will then customize it 4,076 1,458 5,534 Non-Federal governmental plans with less than 500 parti…
  2. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    rough prosecution of a legal suit or action based upon tort or tort type rights, or - 14 - through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 65…
  3. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011
    …s the PERC (premiums, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    …cognized that only one taxpayer should be subject to the tax. H. Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 405, 429; see also Treas. Reg. § 1.2742(f)(2)(iv)(a). Respondent's computations in the Notices of Deficiency fail to take that double payment of tax into account. At the time of the audit of TLC's retur…
  5. T.C. Memo. 2010-186 — Kwame Owusu v. Commissioner
    IRCCourt RulingsAug 23, 2010
    …ent . MEMORANDUM FINDINGS OF FACT AND OPINIO N GALE, Judge : Respondent determined a deficiency of $962 and an addition to tax under section 6651(a)(1) of $145 in petitioner's 2005 Federal income tax .' Petitioner subsequentl y 'All section references are to the Internal Revenue Code of 1986, as in effect for the year …
  6. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …ynch, to protect Taxable income Cash Pay 123,000 Merrill Lynch, to protect Taxable income Other 322,962 Merrill Lynch, to protect Taxable income Total 1,118,870 Petitioners reported taxable income of $213,977, tax of $60,080, tax on IRAs and other retirement plans of $63,717, and total tax 4(...continued) 2000. - 11 - …
  7. 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…
  8. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …élan 419 plan. Respondent calculated those values in accordance with Rev. Proc. 2005-25, 20051 C.B. 962. This is the same as the "accumulated valùe" reported by Indianapolis Life. Petitioners argue that they transferred from one welfare benefit plan to another, that both plans provided for similar benefits with similar…
  9. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  10. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …rvice 4.62 6.26 6.46 6.68 H. Normal cost (beginning of year) 3 7,557,754 8,682,914 9,523,819 11,286,962 I. Benefits paid during year N/A 4,078,160 4,859,441 5,301,930
  11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …n its second year ($4,865.74 x 47.5%). The third-year premium, before any experience refund, was $2,962.50. The policy was credited with an experience refund of $66.69, and the Lakewood Plan paid the net premium of $2,895.81 ($2,962.50 - $66.69). The cost of insuring Dr. Desai for the third year was $665.36, and, at th…
  12. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  13. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978
    … parties and fixed by them as the selling price of the properties. Commissioner v. Patino, 186 F.2d 962, 967 (4th Cir. 1950), affg. 13 T.C. 816 (1949); Evans v. Rothensies, 114 F.2d 958, 962 (3d Cir. 1940); Commissioner v. John C. Moore Corp., 42 F.2d 186,188 (2d Cir. 1930), affg. 15 B.T.A. 1140 (1929). However, this p…
  14. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  15. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …$57,355,200 in storage savings can be attributed to file-size optimization, while an additional $15,962,400 can be attributed to the reduction in reporting frequency. The Departments seek comment on the assumptions made and the estimated storage cost savings for plans and issuers, third-party developers, and other user…
  16. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    … 6651(a)(1) 6651(a)(2) 2002 $10,081 $2,268.22 $2,520.25 2003 19,401 4,365.22 4,850.25 2004 26,498 5,962.05 6,624.50 2005 25,269 5,685.52 6,317.25 2006 23,894 5,376.15 5,973.50 ¹Unless otherwise indicated, section references are to the Internal Revenue Code (Code) applicable for the years at issue. Rule references are t…
  17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  18. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004
    …000 return Mr. and Mrs. Molina reported (1) a $19,620 distribution from the retirement plan, (2) $1,962 of tax on an early
  19. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  20. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…