IRCCourt RulingsApr 18, 1960
…ddition to what he had agreed to accept, namely, $1,000 per month. The case of Howard. Veit, 8 T.C. 809, also cited by the petitioner, is similarly distinguishable.
85 FR 81658 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAFinal Rules (FR)Dec 16, 2020
…ct and Indirect
941
586
1,527
1
1,528
Total
5,005
20,463
25,468
573
26,041
ESOP (No Common Stock)
5,809
5,809
5,809
Common Stock and ESOP
591
591
591
Total All Plans Holding Stocks
5,005
26,863
31,868
573
32,441
a
DOL calculations from the 2018 Form 5500 Pension Research Files.
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
IRCCourt RulingsAug 13, 1999related by meaning
penses which are ordinary
and necessary and recurring in nature. Respondent relies on Rev.
Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring
expenses paid by an employer are not deductible under this
regulation. We disagree.
Our analysis starts at s…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsApr 20, 2017
…Supp. I 2013)) (all using the phrase "against equity and good conscience"). In Groseclose v. Bowen, 809 F.2d 502 (8th Cir. 1987), the court considered
the meaning of "against equity and good conscience" as it appears in 42 U.S.C.
sec. 404(b) (relating to adjustment or recovery of Federal old-age, survivors, and
disabil…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
IRCCourt RulingsDec 5, 2007★ strong match
…ed paid-up insurance
retroactively effective to December 28, 1997, with a face value
- 41 -
of $264,809 . MetLife stated in part that it was making this
change because neither Dr . DeAngelis nor the STEP plan trustee
had received timely notice of either the lapse of the policy or
multidistrict litigation involving MetL…
IRCCourt RulingsFeb 5, 1998
…nerships. On brief, petitioners attached
documents which purport to summarize loans totaling $1,042,809.42
- 12 -
8
The "Officer Loan Payable" account shows a number of
"loans" from Mr. Bach to ISI and shows payments either to Mr.
Bach or to other vendors on behalf of Mr. Bach. The beginning
balance of the Officer Loan…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
rs, as it was required to do. See Frederick Vietor & Achelis v. Salt’s Textile Mfg. Co., 26 F.2d 249, 255 (D. Conn. 1928); O.D. 419, 2 C.B. 60 (1920). What is more, petitioner claimed its foreign tax credit in dollars. It would thus appear that petitioner’s position should be rejected, since section 905(c) speaks in te…
Notice 2020-61 — Special Funding and Benefit Limitation Rules for Single-Employer Defined Benefit Pension Plans under the CARES Act IRCNoticesAug 24, 2020
…riod of time from February 15, 2021, to the extended due date of January 1, 2021, resulting in $249,809 as of January 1, 2021 ($252,945 ÷ 1.1065(45/365)). Therefore, the first $252,945 of that contribution that is used to satisfy the third quarterly installment would result in $236,449 toward satisfaction of the 2020 p…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date 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 equa…
IRCCourt RulingsFeb 9, 2023related by meaning
arties at the original contract date.” Notice 88-123,
1988- 2 C.B. at 477.
145
JJ. T
he 1988 amendment to section 7805 regarding temporary
regulations In 1988, Congress added section 7805(e), which provided:
SEC. 7805 (e). Temporary Regulations. --
(1) Issuance. --Any temporary regulation
issued by the Secretary shall …
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
IRCPrivate Letter RulingsOct 24, 2014
…as reinsured
Colonial Am. Life Ins. Co. v. Commissioner , 491 U.S. 244, 247 (1989).
Treas. Reg. § 1.809-5(a)(7)(ii) defines assumption reinsurance as “an arrangement
whereby another person (the reinsurer) becomes solely liable to the policyholders on
the contracts transferred by the taxpayer. Such term does not include…
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 RulingsMay 11, 2006
… of 2001, petitioner had not attained the age
of 59-1/2.
During 2001, petitioner paid a total of $1,809 in
unreimbursed medical expenses, and petitioner's law partnership
paid on petitioner's behalf health insurance premiums in the
amount of $3,209.
On August 15, 2002, petitioner timely filed her 2001
individual Federa…
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’ …
IRCCourt RulingsAug 12, 1998
…ptember 19, 1990, the plan recognized
as an asset on its balance sheet the new note, at a value of
$809,000. As of the time of trial, the plan had received
payments pursuant to the Collateral Pool Agreement in an amount
somewhat in excess of $200,000. As of the time of trial,
IRCCourt RulingsMay 14, 2001
…eitable, was then only found in the legislative history.
petitioners reported a modified AGI of $77,809 on their 1996
Federal income tax return, they are not entitled to any IRA
deduction if petitioner was an active participant in a plan
during 1996.
Petitioners contend that petitioner was not an active
participant in …