IRCCourt RulingsSep 29, 2022related by meaning
at trial that he had filed a return for 2012 showing tax due.
Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the
amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual
payment …
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…
IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…s
Total cost
burden
SBC with Coverage Examples to Group Health Plan:
Renewal or Application
527,328 263,664
$105,466
$0
$105,466
Sub-total
527,328
263,664
105,466
0
105,466
SBC with Coverage Examples to Participants and Beneficiaries:
Upon Application or Eligibility
2,030,000
1,015,000
406,000
0
406,000
Upon Renewal
58…
IRCCourt RulingsMay 6, 2014
…earing as provided for by
section 301.6320-1(i), Proced. & Admin. Regs. In Kennedy v. Commissioner, 116
T.C. 255, 262-263 (2001), we held that where a taxpayer's request for a CDP
hearing is untimely, the Commissioner's decision to conduct an equivalent hearing
does not waive the time restrictions for requesting such a…
IRCCourt RulingsJun 5, 2014related by meaning
T.C. Memo. 2014-108
UNITED STATES TAX COURT
GUY M. DABNEY AND ANN V. DABNEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14566-12. Filed June 5, 2014.
Guy M. Dabney and Ann V. Dabney, pro sese.
Heather K. McCluskey, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respo…
77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Feb 3, 2012
…
286,000
Investment Disclosure
8,929,000
1,210,000
1,210,000
3,783,000
Update Investment Disclosure
116,000
116,000
116,000
116,000
Investment Disclosure Total
9,045,000
1,326,000
1,326,000
3,899,000
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…
Notice 2022-45 — Notice 2022-45 extends the deadlines for amending an eligible retirement plan (including an individual retirement arrangement or annuity contract) to reflect t… IRCNoticesOct 17, 2022
…t the provisions of section 2202 of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136, 134 Stat. 281 (2020) (CARES Act), and section 302 of Title III of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
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…
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…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
80 FR 48688 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Aug 14, 2015
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 263, as set forth below, is added to the table.
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 annuities
(pe…
IRCCourt RulingsJan 20, 1982related by meaning
Irwin, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the year 1976 in the amount of $549 and an addition to tax under section 6651(a) in the amount of $22. Petitioners concede that respondent properly made an adjustment entitled "Taxes — State and Sales” in the amount of $133 in the n…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…nings thereon) made on June 30, 2018 is payable on January 1, 2020. On December 31, 2018, L pays O $263,097 in accordance with the plan terms. On January 1, 2020, L pays O the remaining account balance of $204,048 in accordance with the plan terms.
(ii) The $263,097 payment made on December 31, 2018 is attributed to se…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsSep 13, 2017
bee v.
Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his
burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the Commissioner's penalty determination is incorrect.
S_e_e Rule 142(a); Welch v. Helvering, 290 U.S. at 115; Higbee v. Commissioner,
116 T.C.…
IRCCourt RulingsJul 25, 1974related by meaning
nal disregard of respondent’s rules and regulations. John Robinson, 51 T.C. 520, 541-542 (1968). We consequently do not sustain the addition for 1965. As for 1966, we think inadequate bookkeeping resulted in the $20,660 understatement of income received from Max Harrison Welfare Plan Consultant, Inc., and that fact cou…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…n-6008-faqs.pdf (Updated April 13, 2020)
Families First Coronavirus Response Act (FFCRA),Public Law 116-127 Coronavirus Aid, Relief, and Economic Security (CARES) Act, Public Law 116-136 Frequently Asked Questions (FAQs) available at
https://www.medicaid.gov/state-resource-center/downloads/covid-19-section-6008-CARE…