86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…0
0938-NEW
326
326
24
7,819
100
783,362
0
783,362
45 CFR 149.460
0938-NEW
75
75
146.67
11,000
101
1,114,612
0
1,114,612
Total
59,914
5,609,057
359,691
19,276,093
1,189,514
20,465,607
H. Submission of PRA-Related Comments
HHS has submitted a copy of these proposed rules to OMB for its review of the rule's information co…
IRCCourt RulingsNov 26, 2007related by meaning
1
All section references are to the Internal Revenue Code, as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure. Amounts are rounded to the nearest dollar.
T.C. Memo. 2007-348
UNITED STATES TAX COURT
CHARLES R. CUTLER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 75…
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…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
85 FR 57123 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Sep 15, 2020
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 324 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a
valuation date
Immediate
annuity rate
(percent)
Deferred annu…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
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…
IRCCourt RulingsMar 20, 1997related by meaning
rences are to
the Internal Revenue Code as in effect for the years at issue,
and Rule references are to the Tax Court Rules of Practice and
Procedure. After concessions, the issues for decision are:
(1) Whether petitioners Milo and Sarah Chapman and David and
Gladys Christie received distributions from the Dura-Craft
p…
IRCCourt RulingsOct 8, 2003related by meaning
f proof in this case
is affected by the fact that we carefully scrutinize transactions
between related parties, Maxwell v. Commissioner
, 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner
, 49 T.C.
649, 656 (1968), remanded pursuant to stipulation of the parties
406 F.2d 290 (6th Cir. 1969), and that…
IRCCourt RulingsMar 31, 1970related by meaning
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
IRCCourt RulingsOct 29, 2020related by meaning
SEC
T.C. Memo. 2020-147
UNITED STATES TAX COURT
RAM RATAN SHARMA AND SHAKUNTALA SHARMA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19466-17. Filed October 29, 2020.
Ram Ratan Sharma and Shakuntala Sharma, pro sese.
Mayer Y. Silber, Elizabeth A. Carlson, and Stanislaw Balazia, for
respondent.…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsDec 2, 2013related by meaning
T.C. Summary Opinion 2013-96
UNITED STATES TAX COURT
SAMUEL BRACH AND LILLIAN BRACH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15460-12S. Filed December 2, 2013.
Ronald Jay Cohen, for petitioners.
Gennady Zilberman, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was h…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCCourt RulingsOct 9, 1997related by meaning
…and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is
not impermissibly broader than sections 419 and 419A and,
accordingly, we hold that it is valid. Chevron U.S.A., Inc. v.
Natural Resources Defense Council, Inc.
, supra
. We have
- 43 -
considered …