IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJul 29, 2003
…00.31.
5
Petitioner rounded his net profit for 1997 from his washing
machine repair business to $30,227. According to the parties’
stipulation of settled issues, the actual net profit for 1997
from that business is $30,227.02.
under section 7491(a), respondent maintains that that burden has
not shifted. That is because…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCProposed Rules (FR)Proposed May 13, 2026
…28,829
47,649
92,654
( printed page 27167)
Small Self-insured (States without Requirements)
312,151
227,870
84,281
163,885
Small Fully insured (States without Requirements)
281,018
205,143
75,875
147,540
77 FR 48855 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Aug 15, 2012
…)
On or after
Before
i1 i2
i3
n1
n2
* * * * * * *
227
9-1-12
10-1-12
0.75
4.00
4.00
4.00
7
8
( printed page 48856)
3. In appendix C to part 4022, Rate Set 227, as set forth below, is added to the table.
Appendix C to Part 4022—Lump Sum Interest Rates For Private-Sector …
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…
ERISAProposed Rules (FR)Proposed Jul 21, 2016
…re/Non-Health
3.3
3.3
1.5
2.5
1.0
Form 5500-SF Small Pension and Non-Health Plans
622.4
622.4
205.8
227.3
21.5
Pension
621.8
621.8
205.6
227.0
21.4
Non-Health Welfare
0.7
0.7
0.2
0.2
0.0
Form 5500 Small Health
6.2
2,158.0
4.1
227.9
223.86
Fully Insured Health
0.0
1,869.0
0.0
69.6
69.6
Other Health
6.2
289.0
4.1
158.2
1…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsOct 9, 1997related by meaning
nd contribution, made
during December 1986, would be deductible in 1986, because that
contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986.
Accordingly, petitioner argues, the regulation contradicts the
plain language of section 419 and is invalid. Petiti…
72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner IRCCourt RulingsJun 11, 1979related by meaning
n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
IRCCourt RulingsAug 26, 1980related by meaning
th the statute and the Congress' policy.
It may be that the regulations could validly prevent such a conditioning of administrative committee consent. This is not an occasion to deliver an advisory opinion as to the validity of a hypothetical regulation, but merely an observation that the status of such a hypothetical …
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsOct 30, 2014
T.C. Memo. 2014-227
UNITED STATES TAX COURT
BRIAN K. BRINKLEY, Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7367-13. Filed October 30, 2014.
William R. Leighton, for petitioner.
Roberta L. Shumway, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a $36…
IRCCourt RulingsJul 24, 1996
…xpenses incurred but unpaid before June 30, 1987. Provident
provided Dorn with the amount of $9,022,227.
Expenses incurred but unpaid before June 30, 1987, for
employees covered under collective bargaining agreements were
included in the $9,022,227. Expenses estimated to be incurred
but unpaid after June 30, 1987, for …
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
…,200 burden hours or an equivalent cost burden of $166,152 to submit withdrawal responses annually.[227]
This results in a total estimated annual burden of 12,600 hours or an equivalent cost burden of $910,392 across both the initiating and non-initiating parties.[228]
As the Departments and OPM share jurisdictions, HH…
IRCCourt RulingsMar 5, 1987related by meaning
ies thereby created.
We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
IRCPrivate Letter RulingsJan 10, 2003
…nsation that can be
deferred under private plans.” (H.R. Report No. 95-1445 at 53 and 59, 1978-3 CB 227
and 233).
85 FR 72934 — Registration Requirements for Pooled Plan Providers ERISAFinal Rules (FR)Nov 16, 2020
…providers report pooled employer plans beginning operation, 453 pooled plan providers * 0.50 hour = 227 hours. 227 hours * $165.63 = $37,598 3,233 * 0.06 = 453 pooled plan providers report pooled employer plans ending operation, 194 pooled plan providers * 0.50 hour = 977 hours. 97 hours * $165.63 = $16,060.
Back to Ci…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…