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104 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …175 .07 Plans involving mergers 175 .08 User fees 175 .09 Interested party notification and comment 176 .10 Contrary authority must be distinguished 176 .11 Employer/employee relationship 176 .12 Incomplete applications 176 .13 Effect of failure to disclose material fact 177 .14 Where to file requests 177 .15 Submissio…
  2. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .
  3. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …herwise have an opportunity to dispute the liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114 T.C. 604, 609 (2000). The phrase "underlying tax liability" includes the tax deficiency, additions to tax, and statutory interest. Katz v. Commissioner, 115 T.C. 329, 339 (2000). In determining whether to sustain the…
  4. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
  5. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981related by meaning
    n was for personal purposes; the petitioners have utterly failed to produce such evidence, and therefore, we sustain the Commissioner’s determination. The final issue for decision is whether any part of the underpayment of tax for 1975 was due to negligence or intentional disregard of rules and regulations within the m…
  6. T.C. Memo. 2002-166 — Wayne A. McFadden v. Commissioner
    IRCCourt RulingsJul 2, 2002
    …e plan. Respondent calculated the outstanding principal plus interest on the Atascadero loan to be $176,276. Respondent computed this figure by adding the principal of the Atascadero loan, $160,701, to the $5,570 outstanding balance of Stephanie’s 1988 loan. The interest on the outstanding amount, as determined by resp…
  7. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  8. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    …. PURPOSE AND OVERVIEW 175 .01 Purpose 175 .02 General principles underlying EPCRS 175 .03 Overview 176 SECTION 2. EFFECT OF THIS REVENUE PROCEDURE ON PROGRAMS 176 .01 Effect on programs 176 .02 Correction of Overpayment (defined benefit plans) 177 .03 Description of other modifications 178 .04 Future enhancements 178 …
  9. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
  10. Notice 2010-83 — Funding relief for multiemployer defined benefit plans under PRA 2010. This notice provides guidance in the form of questions and answers for sponsors of multi…
    IRCNoticesDec 20, 2010
    …ctuarial value of assets on January 1, 2010, prior to applying the 80/120 percent corridor will be $176.78 [$179.65 + (20% * $15) - (40% * $5) + (60% * $0) - (80% * $4.84)]. After applying the 80/120 percent corridor, the actuarial value of assets will be $176.78. This value is the reconstructed hypothetical value of p…
  11. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  12. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024
    …n average, five minutes, resulting in an hour burden of 1,737,781 hours with an equivalent cost of $114,676,201.[82] Table 5—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burden hours Equivalent burden cost Clerical 1,73…
  13. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    r's Life. Respondent further determined that petitioner is liable for the addition to tax under section 6651(a) for his failure to file a 1992 Federal income tax return. - 5 - OPINION Petitioner does not deny receipt of any of the items of income. Nor does he claim that any particular item of income has been overstated…
  14. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997★ strong match
    itioner can show that he comes within one of the exceptions of section 6654(e). Hudson v. Commissioner , 103 T.C. 90, 110 (1994), affd. without - 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears the burden of proof on this issue, Baldwin v. Commissioner , 84 T.C. 859, 871 (1985), and the record cont…
  15. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    … any determination with respect to the underlying liability de novo. Sego v. _9_ [*9] Commissioner, 114 T.C. at 610; Goza v. Commissioner, 114 T.C. 176, 181182 (2000). We review any other administrative determination for abuse of discretion. Craig v. Commissioner, 119 T.C. 252, 260 (2002) (citing Sego v. Commissioner, …
  16. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    IRCCourt RulingsMay 23, 2005related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2001, the taxable year in issue. All monetary amounts are rounded to the nearest dollar. T.C. Summary Opinion 2005-62 UNITED STATES TAX COURT THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v . COMMISS…
  17. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …. 2654; 28 U.S.C. 2461 note (Federal Civil Penalties Inflation Adjustment Act of 1990); and Pub. L. 114-74 at sec. 701. § 825.300 [Amended] 26. In § 825.300 amend paragraph (a)(1) by removing “$173” and adding in its place “$176”. DEPARTMENT OF LABOR Occupational Safety and Health Administration Title 29—Labor PART 190…
  18. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …3d at 675 (citing Tucker v. Commissioner, 676 F.3d 1129, 1135 – 37 (D.C. Cir. 2012), aff’g 135 T.C. 114 (2010) and T.C. Memo. 2011-67); Giamelli, 129 T.C. at 111; Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 182 (2000). That is, we do not substitute our own judgment for that of IR…
  19. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    OPINION COHEN, Judge: Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
  20. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …ith an opportunity to dispute the tax liability. Sec. 6330(c)(2)(B); see also Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114 T.C. 176,.182 (2000). Petitioner has had the opportunity to dispute his income tax liabilities for the years at issue in the - 19 - [*19] deficiency case and is therefo…