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95 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ck to Citation 311.  This estimate is calculated as: $717,127,901 quality-adjusted life years + $31,867,708 in averted healthcare expenditures = $748,995,610 in total undiscounted benefits. Using a 3 percent discount rate, this results in annualized benefits of $637,845,854. Using a 7 percent discount rate, this result…
  2. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  3. PLR 201923016 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsJun 7, 2019
    … Nurseryman Publishing Co. v. Commissioner , supra at 275; Estate of Hill v. Commissioner , 64 T.C. 867, 875-876 (1975), affd. in an unpublished opinion 568 F.2d 1365 (5th Cir. 1978). As the Seventh Circuit explained in Van Den Wy melenberg v. United States , supra at 445 : We re the law otherwise there would exist con…
  4. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  5. U.S. Tax Court — Jeremiah Francis O'Neill v. Commissioner
    IRCCourt RulingsAug 25, 2009
    … irrelevant, then whether the injury arose in military service is simply not a factor . Id . at 866-867 .
  6. PLR 201628004 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    … Nurseryman Publishing Co. v. Commissioner , supra at 275; Estate of Hill v. Commissioner , 64 T.C. 867, 875-876 (1975), affd. in an unpublished opinion 568 F.2d 1365 (5th Cir. 1978). As the Seventh Circuit explained in Van Den Wymelenberg v. United States, supra at 445 : We re the law otherwise there would exist consi…
  7. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  8. PLR 201628006 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    … Nurseryman Publishing Co. v. Commissioner , supra at 275; Estate of Hill v. Commissioner , 64 T.C. 867, 875-876 (1975), affd. in an unpublished opinion 568 F.2d 1365 (5th Cir. 1978). As the Seventh Circuit explained in Van Den Wymelenberg v. United States, supra at 445 : We re the law otherwise there would exist consi…
  9. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  10. PLR 201628005 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    … Nurseryman Publishing Co. v. Commissioner , supra at 275; Estate of Hill v. Commissioner , 64 T.C. 867, 875-876 (1975), affd. in an unpublished opinion 568 F.2d 1365 (5th Cir. 1978). As the Seventh Circuit explained in Van Den Wymelenberg v. United States, supra at 445 : We re the law otherwise there would exist consi…
  11. 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 .
  12. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    …ws: Albert R. Cujas, Jr. Payor Type of Payment Amount Maultsby Orthopedic Clinic PA Compensation $1,867 St. John Neuromuscular Therapy Seminars Compensation 13,214 Matol Botanical International Ltd. Compensation 630 State of N.C. Health Plan Compensation 2,302 Hartford Life Insurance Co. Compensation 677 State Employee…
  13. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …he taxpayer has made no showing o f injury from the reallocation. Davis v. United States , 961 F.2d 867, 878-9 (9 th Cir.1992). “Straitjacketing the IRS into its initial allocation decisions would be inconsistent with the goal of maximizing tax revenues.” Id. at 879. The reallocation may take place during a later year,…
  14. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTE…
  15. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  16. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ion: 1989 1990 1991 1992 1993 Yearend assets $138,653 $137,306 $147,048 $157,095 $164,013 Income 38,867 14,163 13,054 13,087 12,434 Expenses 241 15,510 3,312 3,076 5,516 Contributions 50,030-0 - - 0 - - 0-670 These forms also reported the payment of $11,858, $13,797, $54, zero, and zero in insurance commissions during …
  17. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
    IRCCourt RulingsSep 19, 1978related by meaning
    Tannenwald, Judge: Respondent determined the following deficiencies in petitioner’s Federal income tax: Docket No. TYE— Deficiency 10703-75 ..Oct. 31; 1970 $6,517.00 Oct.. 31, 1971 7,547.00 903-77 .Oct. 31, 1972 2,108.74 Sept. 30, 1973 2,067.29 The sole issue remaining for decision is whether petitioner is barred from …
  18. T.C. Memo. 2020-147 — Ram Ratan Sharma & Shakuntala Sharma v. Commissioner
    IRCCourt RulingsOct 29, 2020
    …ies5 that petitioners received for 2014. These additional adjustments would result in a MAGI of $31,867, and the section 469(i) phaseout would no longer apply. In support of their calculation petitioners cite the instructions for Form 8582.6 The instructions direct taxpayers to calculate their MAGI in the same manner a…
  19. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  20. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …s as follows: Penalty Year Deficiency sec. 6662(a) 2000 $347,369 $69,473 2001 341,566 68,313 2002 2,867,433 573,487 2003 12,869,823 2,573,965 2004 3,731,802 746,360