75 FR 27122 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26 Under the Patient Protection and A… IRCFinal Rules (FR)May 13, 2010
…64
1.42
1.21
Incremental Premium Cost Per Individual Coverage
$3,670
$3,800
$4,000
$3,380
$3,500
$3,690
$3,220
$3,340
$3,510
Impact on Group Insurance Premiums (%)
0.5
0.7
0.7
0.7
1.0
1.0
1.2
1.2
1.1
( printed page 27130)
IRCCourt RulingsOct 17, 1995
…rn
Return
Respondent
Dispute
Advertising -0- $51.54 $26.84 $24.70
Auto expense $2,507.67 5,503.09 2,690.69 2,812.40
Insurance 155.00 155.00 155.00 -0Legal & prof. 432.00 2,635.05 2,635.05 -0Mortg. interest 6,503.89 6,503.89 6,503.89 -0Repairs 4,112.10 5,487.10 5,487.10 -0Taxes 220.00 435.43 435.43 -0Utilities 3,837.35 …
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ies into a taxpayer’s subjective
31
[* 31] motivations. See Hernandez v. Commissioner , 490 U.S. at 690 – 91.
If a transaction is structured such that it is understood that the
taxpayer’s money or property will not pass to the charitable organization
unless the taxpayer receives a specific benefit in return —or the tax…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
…s gain on the 2012 s ale Hoops reported a total
amount realized of $419,394,032, consisting of $200,690,000 of cash ,
$218,704,032 of liabilities assumed by Buyer , and oth er adjustments.
Hoops reported an adjusted basis of $120,370,493 in the assets that it
sold to Buyer. Thus, Hoops recognized gain of $299,023,539 o…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCCourt RulingsMar 12, 2008related by meaning
ified retirement plan during
2002, before he had attained age 59-1/2 . Thus, even if the
additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c),
a point we do not decide, there is ample evidence in the record
to satisfy any burden of production imp…
IRCCourt RulingsAug 24, 1995related by meaning
drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
IRCCourt RulingsAug 24, 1981related by meaning
in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
IRCCourt RulingsApr 18, 1996
…curre ntly deductible items from capital
expenditures. C ommissioner v. Tellier
, 383 U.S. 687, 689-690
(1966). An expense is necessary if it is appropriate and helpful
to the operation of the taxpayer’s trade or business. Carbine v.
Commissioner
IRCCourt RulingsJul 12, 2012
…ckering, but the construction was
finished in 2011. In October 2011 the marital house was sold for $690,000.
Because respondent had an outstanding 1 enÀgainst the marital house with respect
to petitioner and Colleen Gloce i's unpaid tax liability for 2006, the liability at
issue was fully paid from the praceeds. Áfter …
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
IRCCourt RulingsNov 18, 2009
…otice, responden t
determined that petitioners are liable for the 10-percent additional tax on $369,690 .98 of the 2004 IRA distribution that M
Willhite received during 2004 . 2
2In determining in the 2004 notice the 10-percent additional
tax for which petitioners are liable for taxable year 2004,
respondent reduced th…
IRCCourt RulingsSep 22, 1998related by meaning
te minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax und…
IRCCourt RulingsMar 20, 2006
… 624, 631-632 (7th Cir. 1989),
affg. T.C. Memo, 1987-295; Geiger v. Commissioner, 440 F.2d 688,
689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner, 87 T.C. 74, 77 .(1986).
Accordingly, we sustain respondent's determination regarding
IRCCourt RulingsMar 31, 1970related by meaning
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
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…
IRCCourt RulingsJul 22, 1999related by meaning
ursuant to section 72(t).
- 6 -
Section 72(t) provides for a 10-percent additional tax on the
taxable amount of an early distribution from a qualified retirement plan. Section 72(t)(2) provides exceptions to the tax
for certain types of distributions. Petitioners did not offer
any evidence at trial related to this issu…
IRCCourt RulingsMay 14, 2009
… Deficiency Sec . 6651(a)(1) Sec . 6651(a)(2) Sec . 665 4
2002 $9,340 $388 .75
2003 9,354 --
2004 9,690 1,059 .50
1
$245 .83
241 .15
266 .6 9
1 "The amount of the addition to tax per IRC 6651(a)(2)
cannot be determined at this time but an addition to tax of 0 .5
percent will be imposed for each month, or fraction there…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …