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68 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 74 T.C. 651 — Judd v. Commissioner
    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…
  2. 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
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  3. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976related by meaning
    loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
  4. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    ximum of 46% of the combined income to the FSC (by adjusting the sale 1 transfer price). If the profit margin was between 3.98% and 7.96%, the maximum amount of taxable income assignable varied inversely from 46% to 23%, respectively. If the profit margin exceeded 7.96%, they could assign a maximum of 23% of the combin…
  5. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …2,500 98 2,709 99 2,934 100 3,179 101 3,443 102 3,730 103 4,041 104 4,377 105 4,742 106 5,137 107 5,565 108 6,029 109 6,531 110 7,075 111 7,663 112 8,303 113 8,994 114 9,743 115 10,554 116 11,433 117 12,385 118 13,417 119 14,535 120 15,745 121 17,057 122 18,477 123 20,016 124 21,684 125 23,488 126 25,445 127 27,565 128…
  6. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …4.00 The Departments estimate the total one-time year one burden for all issuers and TPAs will be 3,565,380 hours, with an associated equivalent cost of approximately $491,513,100 to develop and build the Prescription Drug File in a machine-readable format. In year two, the Departments estimate the burden and costs to …
  7. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    …npaid are strictly construed in favor of the Government.” (quoting Lucia v. United States, 474 F.2d 565, 570 ( 5th Cir. 1973))); Tice v. Commissioner, No. 24983- 15, 160 T.C., slip op. at 4 (Apr. 10, 2023) (“In effect, a period of limitations runs against the collection of taxes only because the Government, through Con…
  8. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    ayer liable for tax if the taxpayer fails to pay the tax within 10 days after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of the right to a hearing before the levy is made. Se…
  9. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020★ strong match
    …tioners attached to the joint return a Schedule E on which they reported, among other items, a $111,565 loss comprising $109,145 of expenses connected with the rental of three real properties that reportedly produced no income for that year and a $2,420 nonpassive loss from "NYNET CORP". The Schedule E expenses remaini…
  10. Treas. Reg. § 1.403(b)-4(f)(5) — Contribution limitations.
    IRCRegulationsMay 18, 2016
    …2007, the plan refunds the $500 excess along with applicable earnings of $65. (ii) Conclusion. The $565 payment constitutes a distribution of an excess deferral under paragraph (f)(4) of this section. Under section 402(g), the $500 excess deferral is included in E's gross income for 2006. The additional $65 is included…
  11. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …rdinarily prudent person would do under the circumstances. See Rybak v. Commissioner , 91 T.C. 524, 565 (1988); Neely v. Commissioner , 85 T.C. 934,
  12. Treas. Reg. § 54.4971(c)-1(g) — Taxes on failure to meet minimum funding standards; definitions.
    IRCRegulationsDec 30, 2016
    … The excise tax due under section 4971(a) is 10% of the unpaid minimum required contribution, or $5,565. Example 2.(i) The facts are the same as in Example 1. The plan sponsor makes an additional contribution of $175,000 on December 31, 2010. (ii) Under the ordering rule in paragraph (d)(2)(iii) of this section, the co…
  13. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    … .068 .133 .194 .252 .308 .363 .411 .459 .507 .555 54 .069 .135 .197 .256 .313 .369 .418 .467 .516 .565 55 .070 .137 .200 .260 .318 .375 .425 .475 .525 .575 56 .072 .141 .206 .268 .328 .387 .439 .491 .543 57 .074 .145 .212 .27
  14. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997
    …such issue by the application of a reasonableness standard. See Pierce v. Underwood , 487 U.S. 552, 565 (1988) (construing similar language in the Equal Access to Justice Act (EAJA), 28 U.S.C. sec. 2412 (1988)); see also Maggie Management Co. v. Commissioner , 108 T.C. , , (June 11, 1997) (slip op. at 18-19); Sokol v. …
  15. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  16. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022
    …Solutions, Inc . (AMS) , and served in the Air National Guard . AMS paid petitioner $89,977 and $98,565 in 2013 and 2014, respectively, and reported those amounts on Forms 1099 – MISC, Miscellaneous Income. P etitioner also received wages of $5,924 and $6, 3 80 in 2013 and 2014, respectively, from the Dep artment of th…
  17. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
    IRCCourt RulingsSep 2, 2021
    …18 - [*18] ii. Other Expenses a. Assistant Expenses Petitioner reported expenses of $28,219 and $29,565 on her Schedules C as com pensation to her personal assistant, Ms. Giragossian, for tax years 2013 and 2014, respectively. The parties have stipulated these am ounts and that they were in fact paid to Ms. Giragossian…
  18. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  19. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012
    …r expenses". With all "other expenses" combined, respondent increased petitioner's income by $6,154,565 as a consequence of disallowing the claimed deduction of "other - 4 -
  20. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…