110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
w why the statute as
enacted contains language different from that in the House and
- 10 -
1
We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize
this Court to grant a declaratory judgment include secs. 6234,
7428, 7477, 7478, and 7479.
2
Sec. 7503 a…
IRCCourt RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…
IRCCourt RulingsJun 4, 1984
…6.31
Interest accrued, to 12/31/79 Balance due of interest
$11,955.94 $2,269.61
9,625.00 9,625.00
5,129.89 5.129.89
26,710.83 17,024.50
The $17,424.52 outstanding interest as of December 12, 1979, was paid in full in November 1980. Except for the partial $30,000 repayment of principal in 1979, no other repayments of pr…
90 FR 1374 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 8, 2025
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.34071.3
[Amended]
2. In § 4071.3, remove the number “$2,670” and add in its place the number “$2,739”.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYE…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
85 FR 2304 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 15, 2020
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,194” are removed and the figures “$2,233” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MUL…
89 FR 2132 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 12, 2024
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, remove the number “$2,586” and add in its place the number “$2,670”.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER PLAN…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
lculation: 20,830 burden hours × $198.25 ≉ $4,129,476 Note, the total values may not equal the sum of the parts due to rounding.
Back to Citation
719. The Department estimates that 3,531 entities, consisting of 302 retail broker-dealers, 129 non-retail broker-dealers, 85 SEC-registered retail registered investment adv…
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
83 FR 67073 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Dec 28, 2018
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,140” are removed and the figures “$2,194” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MUL…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
88 FR 1991 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 12, 2023
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, remove the number “$2,400” and add in its place the number “$2,586”.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER PLAN…
88 FR 40638 — Quality Control Standards for Automated Valuation Models IRCProposed Rules (FR)Proposed Jun 21, 2023
…1995 and 2022, which are the most recent annual data available. The deflator was 71.300 in 1995 and 129.511 in 2022, resulting in an inflation adjustment factor of 1.82 (129.511/71.300 = 1.816 and $100 million × 1.82 = $182 million).
Back to Citation
187.
Public Law 105–277, 112 Stat. 2681 (1998).
Back to Citation
[FR…
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 …
87 FR 2340 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 14, 2022
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, remove the number “$2,259” and add in its place the number “$2,400”.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER PLAN…
IRCCourt RulingsDec 17, 1992
… a liquidation followed by a change in business form with no true change in ownership. Rev. Rul. 80-129, 1980-1 C.B. 86; see also Rev. Rul. 79-336, 1979-2 C.B. 187. For example, in Revenue Ruling 80-129, the Commissioner ruled that, where a corporation which was wholly owned by two shareholder-employees was liquidated …
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…ates the updated costs as: (124,302 DB plans that use ESG × 1% of plans that have ties × 2 hours × $129.74 per hour for a plan fiduciary) + (124,302 DB plans that use ESG × 1% of plans that have ties × 2 hours × $61.01 per hour for a clerical worker) + (25,020 DC plans that use ESG × 1% of plans that have ties ×
1/3
of…
IRCCourt RulingsMar 27, 1989related by meaning
983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
IRCCourt RulingsMar 5, 2018related by meaning
volution" makes our approach "untenable". See dissenting op. p. 98.
Yet the cornerstone of the dissent's analysis appears to be its highly generalized claim that the purpose of a Roth IRA or an FSC is tax avoidance. See 4 pp. 87,
93. We are unaware of any support, textual or otherwise, for such a generalized
claim with…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
reciated or, having filed a claim, would have acceded to the respondent’s failure to redetermine an overpayment. Cf. Rev. Rul. 58-237,1958-1 C.B. 534. Furthermore, respondent’s position herein corresponds with his announced position of long standing. S.M. 4081, IV-2 C.B. 201 (1925), superseded and reaffirmed in Rev. Ru…