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…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
… the assets reported on its four quarterly financial statements for the preceding year.” See 13 CFR 121.201 (as amended by 84 FR 34261, effective August 19, 2019). In its determination, the “SBA counts the receipts, employees, or other measure of size of the concern whose size is at issue and all of its domestic and fo…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…l entity.
Back to Citation
146.
See 5 U.S.C. 603, 604, and 605. Back to Citation
147.
See 13 CFR 121.201.
Back to Citation
148.
12 CFR part 217.
Back to Citation
149.
12 CFR part 249.
Back to Citation
150.
5 U.S.C. 601
et seq.
Back to Citation
151.
The SBA defines a small banking organization as having $550 mill…
IRCCourt RulingsNov 28, 2023
…ion from a qualified retirement plan. Respondent has filed a
Motion for Summary Judgment under Rule 121, contending that there
are no disputes of material fact and that he is entitled to judgment as a
matter of law. We agree and accordingly will grant the Motion.
Background
The following facts are based on the parties …
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…ternative Investments
(2013) (available at www.oig.dol.gov/public/reports/oa/2013/09-13-001-12-121.pdf);
U.S. Gov't Accountability Office, GAO-12-665, Private Sector Pensions: Federal Agencies Should Collect Data and Coordinate Oversight of Multiple-employer Plans
(2012) (available at
www.gao.gov/assets/650/648…
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…
76 FR 67105 — Cash Balance Plans; Benefit Determinations and Plan Valuations for Statutory Hybrid Plans; Pension Protection Act of 2006 PBGCProposed Rules (FR)Proposed Oct 31, 2011
… part.
(3)
Involuntary termination exception.
If a benefit payment is calculated pursuant to § 4022.121(a)(3)(ii), the benefit will be valued based on the interest crediting rate and the annuity conversion rate in effect under the plan as of the plan's termination date (subject to the rules of §§ 4022.121 through 4022.…
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 …
IRCCourt RulingsOct 11, 1995related by meaning
T.C. Memo. 1995-492
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed October 11, 1995.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Jud…
IRCCourt RulingsSep 17, 2026
…trials. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C . 73, 74 (2001). Ordinarily, under
Rule 121(a)(2) the Court may grant summary judgment when there is
no genuine dispute as to any material fact and the movant is entitled to
judgment as a matter of law . Sundstrand Corp. v. Commissioner, 98
T.C. 518, 520 (1992…
IRCCourt RulingsMar 10, 2020related by meaning
ery conceivable basis which might support'" the legislative arrangement under
section 72(t). Estate of Kunze v. Commissioner, 233 F.3d at 954 (quoting Taxation With Representation of Wash., 461 U.S. at 548). Applying the section
72(t) additional tax to the qualified retirement plan distributions Ms. Conard
received in …
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 601(3) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
100.
Medical Expenditure Panel Survey Insurance Component, Agency for Healthcare Researc…
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…
IRCProposed Rules (FR)Proposed May 13, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
186.
13 CFR 121.201 (2011).
Back to Citation
187.
15 U.S.C. 631
et seq.
(2011).
Back to…
IRCCourt RulingsApr 12, 1979related by meaning
e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
43.
13 CFR 121.201 (2011).
Back to Citation
44.
15 U.S.C. 631
et seq.
(2011).
Back to C…
ERISACourt RulingsJan 20, 1998
…7; for a 92 day period (October 19,
1987 to January 1, 1988) at 7% interest yields $3,016.44; for a 121
day period (January 18, 1988 to May 17, 1988) at 6.65% interest
yields $3,763.97; for a 121 day period (May 17, 1988 to September
14, 1988) at 6.75% interest yields $3,820.57; and for a 365 day
period (September 14, …
IRCCourt RulingsDec 18, 2012
… Court disagrees
with this treatment, the respective deficiencies are $108,656, $67,059, $126,860, $121,404, $154,258, and $117,884.
We decide the following issues:4
1. whether petitioners' gross income for the subject years includes
nonemployee compensation of $483,591, $487,873, $536,145, $628,500,
$694,986, and $815…
IRCCourt RulingsNov 10, 1998related by meaning
1
All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
T.C. Memo. 1998-399
UNITED STATES TAX COURT
RONNY H. AND CHARLOTTE A. SCHMALZER, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21…