IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…
5,461
5,461
5,461
5,461
5,461
5,461
5,461
54,609
= Assets Retained
127
259
375
454
494
534
575
596
617
617
4,647
Present Value of Assets Retained by Discount Rate:
3 Percent
123
244
343
403
426
448
468
470
473
459
3,856
7 Percent
118
226
306
346
352
356
358
347
335
313
3,059
Table 5
B
—Value of Affected Accounts
[$ in…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsJul 14, 2005related by meaning
0 31
useaee
CAL,
Js.r. Juoca
T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ars
Activity
Burden hours
Equivalent
burden cost
Burden hours Equivalent
burden cost
Clerical
41
$2,617
13
$793
Total
41
2,617
13
793
1.7 Overall Summary
The paperwork burden estimates are summarized as follows:
Type of Review:
Revision of an existing collection.
Agency:
Employee Benefits Security Administration, Depar…
IRCCourt RulingsApr 22, 2003related by meaning
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
ERISAProposed Rules (FR)Proposed Nov 21, 2022
…onal Office, J.F.K. Federal Building, 15 New Sudbury Street, Room 575, Boston, MA 02203, telephone (617) 565-9600, fax: (617) 565-9666; jurisdiction: Connecticut, Maine, Massachusetts, New Hampshire, central and western New York, Rhode Island, Vermont.
Chicago Regional Office, John C. Kluczynski Federal Building, 230 S…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…labor rate is applied in the following calculation: (165 × (15 minutes ÷ 60 minutes)) × $63.45 = $2,617.
Back to Citation
497.
The burden is estimated as: (50 × (15 minutes ÷ 60 minutes)) = 12.5 hours. A labor rate of $63.45 is used for a clerical worker. The labor rate is applied in the following calculation: (50 × (…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…s will opt in respectively in Nevada, Virginia, Washington, and New Jersey, resulting in a total of 617 self-insured plans.[213]
These plans will incur the one-time burden and cost to include the disclosure in their plan documents in 2022.
DOL estimates that it will take 1 hour for an administrative assistant, with a w…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…
Beneficiaries Living Apart
90,000
90,000
1,500
44,400
1,500
44,400
Sub-total
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
19,313,9…
Notice 2009-68 — Safe harbor explanations — eligible rollover distributions. This notice contains two safe harbor explanations that may be provided to recipients of eligible ro… IRCNoticesSep 28, 2009
…e Code that affect the information required to be provided in a § 402(f) notice, including sections 617 and 657 of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), P.L.107-16, and sections 824, 827, 828, 829, and 845 of the Pension Protection Act of 2006 (PPA ’06), P.L. 109-280. Section 617(a) of…
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 RulingsAug 27, 2026
… Mr. Janangelo claimed $23,354 in
expenses :
2018 Expense Amount
Insurance ( o ther t han h ealth) $617
Legal and P rofessional Services 16,844
Supplies 347
Other Expenses (including Drake T ax software, CPE expenses , b ar and
union d ues, license renewal s , and periodicals )
5,546
V. 2019, 2020, and 2021: Other Adju…
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…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
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 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 RulingsMar 7, 2019
…-- -- -- -- -- E
GPS System 10/7/2004 1,739 1,739 -- -- -- -- -- E
BA463 2005 Mustang 11/20/2004 28,617 -- -- 2,960 4,700 2,850 1,675 E
Equipment--Sears 2/26/2005 3,880 3,880 -- -- -- D
BA201 2001 Mustang 5/6/2005 11,500 800 -- 2,140 3,424 2,054 1,233 E
Computer Equipment 7/22/2005 1,948 1,948 -- -- -- -- -- Concedes
F…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…