IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
81 FR 38020 — Expatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Dura… IRCProposed Rules (FR)Proposed Jun 10, 2016
…29 CFR 2590, and 45 CFR parts 144 and 147. This document clarifies an exemption set forth in 45 CFR 153.400(a)(1)(iii) related to the transitional reinsurance program. Section 1341 of the Affordable Care Act provides for the establishment of a transitional reinsurance program in each State to help pay the cost of treat…
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
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Respondent does not dispute that petit…
IRCCourt RulingsOct 20, 2003
…all Rule references are to the Tax
Court Rules of Practice and Procedure.
T.C. Summary Opinion 2003-153
UNITED STATES TAX COURT
JOSEPH JONES, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12825-02S. Filed October 20, 2003.
Joseph Jones, pro se.
Travis Vance III
, for respondent.
ARMEN, Special …
IRCCourt RulingsMar 19, 2025related by meaning
United States Tax Court
T.C. Memo. 2025-23
CHARLIE CAMPANA,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
__________
Docket No. 15766-23. Filed March 19, 2025.
__________
Charlie Campana , pro se.
Bianca L. Thomas and Daniel C. Munce, for respondent.
MEMORANDUM FINDINGS OF FACT A ND OPINION
PUGH , Judge : …
IRCCourt RulingsJan 2, 2020related by meaning
principles and to deter the waste of judicial resources. See Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of
the potential implications of continuing to assert frivolous and groundless
arguments. For…
IRCCourt RulingsFeb 2, 2022
…aff, and Mr. Makov were going to act “as one, unanimously” when
5
Mr. Larson objec ts to paragraphs 153 through 157 of the joint stipulation of
facts dated January 10, 2020, on the grounds that they are not relevant. These are
facts that are of consequence to the determination of the action within the meaning of
Rule 4…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCourt RulingsMar 24, 1980
…0 651,577.32 942,047.46 1,185,666 989,516
Profit-sharing 58,595.30 96,206.43 139,191.71 175,510 146,153
Total 456,841.30 747,783.75 1,081,239.17 1,361,176 1,135,749
Andrew J. Homer
Salary $12,000.00 $12,000.00 $12,000.00 $12,000 $12,000
Commission 44,519.40 73,769.90 106,750.85 153,640 208,012
Bonus 5,651.94 8,576.99 1…
ERISACourt RulingsFeb 22, 2000
…ived an annual, individual participant statement
through 1992, but they ceased after that. (T 152 - 153)
Ms. Palaoro stated that she received the 1991
statement in 1993. Plan years 1990 had three revisions and 1991 had
two after that. She left on July 29, 1992, and made her first
request for the 1992 annual statements …
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
IRCCourt RulingsApr 2, 2020
…chedule is the claim made on the Form 843 in
September 2011, which Goldberg refers to in the Form 12153.
- 153 -
[*153] Goldberg's Form 843. Morgan documented spending 11.75 hours on
Goldberg's claim during this four-month period and a total of 15.25 hours from
the date Goldberg filed his Form 12153 to when the notice …
IRCCourt RulingsFeb 6, 2024related by meaning
icipation. Id.
Thus, even though the withdrawal from the taxpayer’s Keogh account
was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively
receive the funds under section 72(m)(4)(A).
4
In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption) ERISAFinal Rules (FR)Apr 3, 2024
… for the whole universe of small plans, then that would indicate a further (10/1,267) × 652,934 = 5,153 additional unique QPAMs used exclusively by small Plans.
Back to Citation
83.
The number of unique QPAMs is calculated as: 5,702 QPAMs found on the 2020 Form 5500 Schedule C + 5,153 QPAMs estimated as servicing excl…
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
87 FR 58968 — User Fees Relating to Enrolled Agents and Enrolled Retirement Plan Agents IRCFinal Rules (FR)Sep 29, 2022related by meaning
lt in expenditures by state, local, or tribal governments, or by the private sector in excess of that threshold.
IV. Executive Order 13132: Federalism Executive Order 13132 (Federalism) prohibits an agency from publishing any rule that has federalism implications if the rule either imposes substantial, direct complianc…
IRCCourt RulingsJan 28, 2014related by meaning
her traditional IRA, a qualified retirement plan for purposes of
section 72(t). S_ee sec. 4974(c)(4). Petitioner wife had not attained age 59½ at the time of the July 31, 2008, distribution. Petitioner wife has not shown that she
qualifies for any of the other exemptions in section 72(t)(2). See Phillips v.
Commission…
IRCFinal Rules (FR)Nov 12, 2020
…with providers, or for the purpose of submitting data in accordance with the requirements of 45 CFR 153.710(c).
Title 45 CFR 153.710(c) sets forth a process through which capitated plans that do not generate individual enrollee claims in the normal course of business must submit data for the purpose of the HHS-operated…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
er 1 as determined under subsection (e)
by substituting —
(i) in paragraph (1)(A), “200 percent”
for “150 percent” . . . .
2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which
all accuracy-related penalties are imposed on underpayments of tax.
Section 6662(b) lists the penalizab…
80 FR 41318 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 14, 2015
…, The Epidemiology of Vaccination.
Back to Citation
59.
Unhealthy U.S. Workers' Absenteeism Costs $153 Billion. Well-Being, Gallop October 17, 2011 at
http://www.gallup.com/poll/150026/Unhealthy-Workers-Absenteeism-Costs-153-Billion.aspx.
Back to Citation
60.
Ibid,
see e.g.,
Health and Productivity Among U.S. Work…