IRCCourt RulingsSep 13, 1990
…on
(pre-ERTA)(500,000)(400,000)(300,000)
Taxable estate500,000 400,000 300,000
Tentative tax155,800 121,800 87,800
Unified credit121,800 121,800 121,800
Estate tax due34,000
Unused credit34,000
IRCCourt RulingsOct 11, 1957related by meaning
s that its enforcement would amount to a deprivation of property without due process of law as required under the Fifth Amendment to the Constitution. We have carefully considered the decision of the Seventh Circuit in the Kohl case, and its application as a precedent in the problem which confronts us. With all due res…
78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCProposed Rules (FR)Proposed Mar 21, 2013
…, other than § 146.130 and the provisions with respect to genetic nondiscrimination (found in § 146.121(b), § 146.121(c), § 146.121(e), § 146.122(b), § 146.122(c), § 146.122(d), and § 146.122(e)) do not apply to any group health plan (and group health insurance coverage) for any plan year, if on the first day of the pl…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
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 RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsApr 26, 2012related by meaning
ed in section 274(d). Sanford v. Commissioner, 50 T.C. 823, 827 (1968),
aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); Rodriguez v. Commissioner, T.C. Memo. 2009-22 (the strict substantiation requirements of section 274(d) preclude
the Court and taxpayers from approximating certain expenses).
r
- 12 -
Petitioners' tabl…
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013
…low-risk and high-risk entities. The burden for low-risk sponsors would go down from 417 hours and $121,725 to zero. The burden for high-risk sponsors
( printed page 20059)
would go up by approximately 760 hours and $157,100.
Low-risk
Volume
Hours
Cost
Current
144
417
$121,725
Proposed
0
0
$0
Change
(144)
(417)
(121,72…
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
…(B)
(A × B)
(C)
(A × B × C)
(D)
(A × D)
Service providers prepare information (non-bulk)
326
2
652
$121.53
$79,238
$10.10
$3,293
Service providers prepare information (bulk)
2
20
40
121.53
4,861
10.10
20
Service providers maintain recordkeeping for SCC
909
0.17
152
121.53
18,412
Total
1,237
844
102,511
3,313
VFCP Class…
IRCCourt RulingsJul 29, 1997related by meaning
ions. Respondent determined that
such additional tax was due from petitioner on account of his
receipt of the 1992 distribution and the U.S. Trust Co. distribution. With respect to the U.S. Trust Co. distribution,
respondent now concedes that only $638 of that distribution is
subject to the additional tax.
Petitioner h…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…stration Office of Advocacy in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c) in a memo dated June 4, 2020.
Back to Citation
116.
13 CFR 121.201 (2011).
Back to Citation
117.
15 U.S.C. 631
et seq.
(2011).
Back to Citation
118.
0.5 hours * $134.21 + 0.5 hours * $55.14 = $94.68.
Back t…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
…a national bank or Federal savings association as a small entity.
Back to Citation
65.
See 13 CFR 121.201. Effective July 14, 2014, the SBA revised the size standards for banking organizations to $550 million in assets from $500 million in assets. 79 FR 33647 (June 12, 2014).
Back to Citation
66.
See 12 CFR part 21…
IRCCourt RulingsDec 2, 2013related by meaning
T.C. Summary Opinion 2013-96
UNITED STATES TAX COURT
SAMUEL BRACH AND LILLIAN BRACH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15460-12S. Filed December 2, 2013.
Ronald Jay Cohen, for petitioners.
Gennady Zilberman, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was h…
83 FR 46642 — Mergers and Transfers Between Multiemployer Plans PBGCFinal Rules (FR)Sep 14, 2018
…er plans and to improve the financial condition of PBGC's multiemployer insurance program. Sections 121 and 122 of MPRA provide that PBGC may assist financially troubled multiemployer plans under certain conditions.[1]
This rule is necessitated by section 121 of MPRA.
Section 121 of MPRA authorizes PBGC to facilitate m…
IRCCourt RulingsFeb 15, 2002related by meaning
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…assets of the concern whose size is at issue and all of its domestic and foreign affiliates. 13 CFR 121.103(6).
Back to Citation
267.
13 CFR 121.201.
Back to Citation
268.
5 U.S.C. 601
et seq.
Back to Citation
269.
The SBA defines a small banking organization as having $600 million or less in assets, where “a financ…
IRCCourt RulingsApr 30, 1997related by meaning
itioner can show
that he comes within one of the exceptions of section 6654(e).
Hudson v. Commissioner
, 103 T.C. 90, 110 (1994), affd. without
- 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears
the burden of proof on this issue, Baldwin v. Commissioner
, 84
T.C. 859, 871 (1985), and the record cont…
85 FR 81658 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAFinal Rules (FR)Dec 16, 2020
120.
29 CFR 2509.2008-2 (73 FR 61731 (Oct. 17, 2008)).
Back to Citation
121.
EBSA estimates using 2018 Form 5500 filing data.
Back to Citation
122. The burden is estimated as follows: 63,911 plans * 0.5 hours = 31,955.4 hours for both a plan fiduciary and clerical staff. A labor rate of $134.21 is used for a plan f…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
IRCCourt RulingsAug 8, 2005related by meaning
T.C. Memo. 2005-192
UNITED STATES TAX COURT
ARTHUR F. MILLARD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3713-04. Filed August 8, 2005.
Arthur F. Millard, pro se.
Travis T. Vance III
, for respondent.
MEMORANDUM OPINION
WELLS, Judge
: Respondent determined a deficiency of $2,764
in petition…