IRCCourt RulingsJul 26, 1989related by meaning
OPINION
COHEN, Judge:
Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
85 FR 40834 — Improving Investment Advice for Workers & Retirees ERISAProposed Rules (FR)Proposed Jul 7, 2020
pact of the proposed exemption on small entities.
In December 2018, there were 985 small-business BDs and 528 SEC-registered, small-business IAs.[175] The Department estimates that approximately 52 percent of these small-businesses will be affected by the proposed exemption.[176]
In December 2018, the Department estima…
IRCCourt RulingsJan 14, 2013
letcher
1973-1983 -0- -01984 $6,000 -01985 13,000 $12,923
1986 15,521 18,764
1987 26,769 29,077
1988 36,000 36,000
1989 36,000 36,000
1990 4,154 4,154 1991 -0- -01992 20,800 -01993 20,800 -06All amounts have been rounded to the nearest whole number. No Forms W2 were presented for any year where the amount paid was "-0-…
IRCCourt RulingsJun 16, 1987related by meaning
GOFFE, Judge:
The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
IRCCourt RulingsJun 17, 1997
…t. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536
DWB's (amount) 0
11,985
682,394
640,125
727,947
671,783
2,734,234
Total 468,274
2,304,351
4,531,057
11,372,646
6,954,975
4,789,467
30,420,770
B. Suspense Account transactions
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 — …
Rev. Proc. 2017-18 — This revenue procedure provides that the last day of the remedial amendment period for § 403(b) plans, for purposes of section 21 of Rev. Proc. 2013–22, 2013–1… IRCRevenue ProceduresModified Jan 30, 2017
…endment period for § 403(b) plans, for purposes of section 21 of Rev. Proc. 2013–22, 2013-18 I.R.B. 985, is March 31, 2020. The selection of the last day of the remedial amendment period for § 403(b) plans was reserved in section 21 of Rev. Proc. 2013–22 (setting forth the procedures for issuing opinion and advisory le…
IRCCourt RulingsSep 30, 1991related by meaning
tioners to believe that no taxable event was created by the above transactions for which any Federal excise tax returns would be required to be filed. On November 21, 1986, respondent issued a notice of deficiency to each petitioner, in the amounts set forth above, determining an excise tax pursuant to section 4975(a).…
Rev. Proc. 2015-22 — This revenue procedure contains a modification to Revenue Procedure 2013–22, 2013–18 I.R.B. 985, as modified by Revenue Procedure 2014–28, 2014–16 I.R.B. 944, … IRCRevenue ProceduresMar 16, 2015
…PURPOSE
This revenue procedure contains a modification to Revenue Procedure 2013–22, 2013–18 I.R.B. 985, as modified by Revenue Procedure 2014–28, 2014–16 I.R.B. 944, and modifications to Revenue Procedure 2015–8, 2015–1 I.R.B. 235. In particular, this revenue procedure changes the addresses to which applications for o…
IRCCourt RulingsDec 18, 2012
…- 11 -
[*11] Account 1992 1993 1994 1995 1996 1997
BOA3721 -0- $3,206 $2,000 $875 -0- -0BOA3886 $66,985 28,531 15,793 224,873 $73,281 $11,593
CB9250 -0- -0- 68,843 15,900 15,716 -0FFB0488 -0- 400,296 221,847 -0- -0- -0FFB0991 -0- -0- -0- 500 -0- -0FFB1604 -0- -0- 415,339 769,501 519,925 -0FFB2520 -0- -0- -0- 139,412 84…
Rev. Proc. 2014-28 — This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing o… IRCRevenue ProceduresApr 14, 2014
…Proc. 2014–28
SECTION 1. PURPOSE
This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing opinion and advisory letters for § 403(b) pre-approved plans (that is, § 403(b) prototype plans and § 403(b) volume submitter pla…
IRCCourt RulingsAug 27, 2026
…ors
20
See § 7463(b) ; Rule 170; Golsen v. Commissioner, 54 T.C. 742, 757 (1970),
aff’ d , 445 F.2d 985 (10th Cir. 1971).
22
do not apply or are neutral . No single factor or group of factors is
dispositive , and more weight may be given to some factors than others.
Golanty , 72 T.C. at 426; see also Surridge v. Commis…
IRCCourt RulingsAug 28, 1996related by meaning
…r the 1991
excise tax deficiency. Sec. 6213; Stamm Intl. Corp. v.
Commissioner
, 84 T.C. 248, 252 (1985). Questions of jurisdiction
must be decided whenever it appears that we may not have
jurisdiction. Wheeler's Peachtree Pharmacy, Inc. v.
Commissioner
, 35 T.C. 177, 179 (1960).
Section 6212, in pertinent part, provid…
IRCProposed Rules (FR)Proposed May 13, 2026
…nts)
401,392
293,016
108,376
210,739
Fully insured (States without Requirements)
314,761
229,775
84,985
165,256
Total Private
933,803
681,677
252,127
490,266
All Plans
995,792
726,928
268,864
522,811
* Totals displayed in the table may not sum due to rounding.
1
Estimated from the KFF
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…615,037 Additional Paper DC Statement Cost (5 Pages)
$0
$42,958,993
$37,214,880
$34,420,082
$38,197,985
Total Additional Costs
$0
$47,024,610
$40,736,877
$37,677,581
$41,813,022
Table 15—Pension Benefit Statement Burden Summary
Hourly burden
Cost burden
Baseline Burden to Distribute Benefit Statements
$374,708,891
Ad…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsMay 14, 2001related by meaning
…of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equaling one-half" of her former spouse's Coast Guard
retirement p…
PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsSep 25, 2009
… money periodically over a term of years or for life. See , e.g .,
Bodine v. Comm’r , 103 F.2d 982, 985 (3d Cir.), cert. denied , 308 U.S. 576 (1939) (“[A]n
annuity may be described as a sum paid yearly or at other specified intervals in return
for the payment of a fixed sum by the annuitant.”); Manne v. Comm’r , 155 F…
IRCCourt RulingsMay 19, 2011related by meaning
… that he is entitled to judgment as a matter of law. See
Naftel v. Commissioner, 85 T.C. 527, 529 (1985). In deciding
whether summary judgment is appropriate, we view the factual
materials and the inferences drawn therefrom in the light most
favorable to the nonmoving party. United States v. Diebold,
Inc., 369 U.S. 654…