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Go to 64 T.C. 663 (not yet in the library — opens the official source)
83 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …stion of fact to be resolved on the basis of the entire record. See Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). Because there is rarely a substantial market for sales of easements comparable to the donated easement , courts typically value conservation easements indirectly using a “before and after” approach . See…
  2. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  3. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …ociated with new QPAMs meeting the policies and procedures requirements of the QPAM Exemption is $1,663.[77] QPAM-Sponsored Plans—Independent Audit—Section V(c)
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … question of fact to be resolved on the basis of the entire record. Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). To support their positions regarding valuation, the parties retained experts. We assess an expert ’ s opinion in the light of the expert’s qualifications and the evidence in the record. See Parker v. Com…
  5. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  6. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …articipating provider at a participating facility,[185] the Departments estimate that approximately 663,436 individuals will have the potential to be treated by a nonparticipating provider or facility. In the absence of data, the Departments assume that in 50 percent of cases services will be provided by nonparticipati…
  7. Treas. Reg. § 1.404(a)-12(b)(3) — Contributions of an employer under a plan that does not meet the requirements of section 401(a); application of section 404(a)(5).
    IRCRegulationsMay 18, 2016
    … accounts must be sufficiently separate and independent to qualify as separate shares under section 663(c). Nothing shall preclude a trust which loses its exemption under section 501(a) from setting up such acounts and meeting the separate account requirement of section 404(a)(5) with respect to the taxable years in wh…
  8. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  9. Treas. Reg. § 1.436-1(g)(6) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …lication of the restriction on plan amendments under paragraph (c) of this section. Therefore, $105,663 (that is, the $196,048 actual contribution paid on February 1, 2011, minus the $90,385 required contribution based on the actual AFTAP) is recharacterized as an employer contribution under section 430 for the 2011 pl…
  10. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
  11. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …Table 16—General Data Description Assumption Source Number of Small Defined Contribution (DC) Plans 663,107 2022 Form 5500 Data. Number of Small Defined Benefit (DB) Plans 40,117 2022 Form 5500 Data. All Participants in Small Plans 14,588,887 2022 Form 5500 Data. Service Providers for Accounting, Actuarial Services, an…
  12. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  13. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …S.C. § 1132(g)(1) (emphasis added); see also Plasterers’ Loc. Union No. 96 Pension Plan v. Pepper , 663 F.3d 210, 221– 22 (4th Cir. 2011) . Kelly also argues the district court failed to properly apply the Quesinberry factors and failed to consider the remedial purposes of ERISA and its fee analysis . But we find the d…
  14. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  15. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …S.C. § 1132(g)(1) (emphasis added); see also Plasterers’ Loc. Union No. 96 Pension Plan v. Pepper , 663 F.3d 210, 221– 22 (4th Cir. 2011) . Kelly also argues the district court failed to properly apply the Quesinberry factors and failed to consider the remedial purposes of ERISA and its fee analysis . But we find the d…
  16. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …nit determined petitioners' monthly gross income, monthly expenses, and monthly net income to be $8,663, $8,225, and $438, respectively. On the basis of petitioners' net realizable equity of $19,342.80 and monthly net
  17. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …of 7.00%. Ex. C36. 13Interest that had accrued to January 1, 1988 on these CDS in the amount of $42,663.10 was deposited in the Plan's account on January 20, 1988. Ex. C18. CD No. 11813-17735 was outstanding from January 1, 1988 to May 18, 1988 at an annual interest rate of 6.65%. Ex. C15. 14CD No. 11813-17916 was outs…
  18. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  19. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …evant items: 2001 2002 2003 Compensation of officers $379,000 $411,400 $500,000 108 213 125,266 138,663 Salaries and wages Pension, profit-sharing, 27 299 22,731 21,789 etc., plans - 8 - Employee benefit programs -- --t - Consultant fees 99,000 90,453 101,000 For the years at issue Diogenes reported the following relev…
  20. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…