81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…t, $100, by the inflation adjustment factor for 1927 of 13.66885, which resulted in a penalty of $1,367 (rounded to the nearest dollar). The amount of the increase from existing § 702.236's $110 penalty to $1,367 is $1,257, which would be more than the statutory cap of 150 percent of the existing $110 penalty, which is…
IRCCourt RulingsFeb 25, 1959related by meaning
y at the time it was terminated and hence section 165 (b) did not apply. Eespondent has cited no case which would require a different conclusion here. On the facts here involved it is our opinion that the distribution received by petitioner in the year 1955 was paid to him on account of his separation from the service …
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…60,120,000
36,975,000 617,750
18,285,400
617,750
18,285,400
Uniform Glossary
1,102,000
1,102,000
18,367
543,653
18,367
543,653
Notice of Modification
1,160,000
719,200
11,987
354,805
11,987
354,805
Total
62,909,328
39,059,864
652,498
19,313,933
652,498
19,313,933
The Departments note that persons are not required to re…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
IRCRegulationsJul 9, 2026
…oration (target C corporation) that actively conducts a trade or business within the meaning of § 1.367(a)-2(d)(2) and (3);
(c)(2)(v)(B) (B) Immediately before the acquisition, the target C corporation does not engage in a trade or business of investing in interests in life insurance contracts;
(c)(2)(v)(C) (C) Immedia…
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
.
IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
IRCCourt RulingsSep 24, 2007★ strong match
)(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…
Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum… IRCRevenue RulingsNov 26, 2007related by meaning
INCOME TAX
T.D. 9362 T.D. 9362
Temporary and proposed regulations under section 905 of the Code provide rules relating to a United States taxpayer's obligation to notify the Internal Revenue Service of a foreign tax redetermination, which is a change in foreign tax liability that may affect the taxpayer's foreign tax c…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsDec 8, 1987related by meaning
ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468.
Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
IRCCourt RulingsMar 31, 2008
…f creating a debtor-creditor relationship" .
Litton Bus . Sys ., Inc . v . Commissioner , 61 T .C . 367, 377 (1973) .
Petitioner must prove that a bona fide debt was created and that
the distribution he received in 2001 from the Kaiser USWA ESOP
was the repayment of a loan . See Rule 142(a) ; see also sec .
7491(a) .
T…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCCourt RulingsJul 31, 2000
…hey would
otherwise be deductible as a business expense. See Carbine v.
Commissioner
, 83 T.C. 356, 367-368 (1984) (and cases cited
thereat), affd. 777 F.2d 662 (11th Cir. 1985); Glassner v.
Commissioner
, 43 T.C. 713, 715 (1965), affd. per curiam 360 F.2d
33 (3d Cir. 1966); sec. 1.264-1(a), Income Tax Regs.
Respondent…
IRCCourt RulingsSep 14, 1993related by meaning
r in the computation of the sec. 72(t) tax, her petition raised the issue whether she should have been subject to any additional tax under sec. 72(t). Sec. 402(e)(1) has been redesignated sec. 402(d) by the Unemployment Compensation Amendments of 1992, Pub. L. 102-318, sec. 521(a) and (b), 106 Stat. 290, 300-310, 313, …
IRCCourt RulingsOct 25, 1999
…ations, and
judicial case law and not informal IRS sources. See Zimmerman v.
Commissioner
, 71 T.C. 367, 371 (1978), affd. without published
opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner
, 59
T.C. 456, 458 (1972). Additionally, in order to ensure uniform
enforcement of the tax law, the Commissioner must f…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCCourt RulingsJun 17, 1997
…40,673 $571,125 $672,543 $622,323 $639,859
Compensation of officers 164,000 327,000 450,000 315,000 367,000
Salaries & wages 86,551 36,600 42,656 23,247-0 -
Pension, profit-sharing, plans 73,462 77,769 93,556 160,351 102,506
Employee benefit programs 17,368 56,230 6,761 9,418 5,425
Taxable loss 2,444 12,549 24,327 20,9…
IRCCourt RulingsDec 18, 2012
…s or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir. 1985), aff'a T.C. Memo. 1984-367.
Respondent did not request that the Court impose a penalty pursuant to
section 6673, and we exercise our discretion not to consider or impose a section
6673 penalty on petitioners in these cases. We sternly warn pet…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …