IRCCourt RulingsNov 7, 2003related by meaning
t petitioner was liable for this
additional tax. Respondent determined that the distributions
simply constituted income for the amounts set out in the information returns filed by the payor, Sunoco. Moreover,
petitioner's health status and his need for the money are not
grounds for the exclusion of the distributions fr…
IRCCourt RulingsMar 31, 1997related by meaning
ons of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
- 3 - After concessions, the following 2 issues remain for us to
resolve in the present proceeding: (1) Whether petitioner, in
its taxable year ending January 30, 1988 (TYE 88…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…ty selection is required—70 percent (527,800) disputes initiated by the top 10 initiating parties = 226,200 disputes for other initiating parties. 226,200 disputes/52,214 small providers/facilities = 4 disputes per small provider annually. 4 disputes × −$30.01 = −$120 per small provider.
Back to Citation
331.
This is …
IRCCourt RulingsOct 21, 2003related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-157
UNITED STATES TAX COURT
DARRELL R. FULCHER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14140-01S. Filed October 21, 2003.
Darrell R. Ful…
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
…FC Program applicants involving Lost Earnings less than or equal to $1,000.
Back to Citation
39.
1,226 applicants × 73.4% × 1.01 = 909 self-corrections.
Back to Citation
40.
1,226 applicants × (100% minus 74.3%) = 326 non-bulk applicants.
Back to Citation
41.
The Department estimates that the SCC will streamline the…
IRCProposed Rules (FR)Proposed Jul 19, 2024
…58−$1,000.00). In this case, for the second determination year, the adjusted account balance is $97,226.42 ($100,000.00−$2,773.58) and the hypothetical required minimum distribution for 2032 is $3,812.80 ($97,226.42/25.5). For 2033 (the year in which B reaches age 75), the adjusted account balance is calculated by redu…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
88 FR 40638 — Quality Control Standards for Automated Valuation Models IRCProposed Rules (FR)Proposed Jun 21, 2023
64, subpart B; Board: 12 CFR 226.43; NCUA: 12 CFR 722.3(a); FHFA: 12 CFR part 1222, subpart A. The FDIC adopted the CFPB's version of the regulations. See 78 FR 10368, 10370 (Feb. 13, 2013).
Back to Citation
171.
15 U.S.C. 1639e (added by Dodd-Frank Act section 1472).
Back to Citation
172.
CFPB: 12 CFR 1026.42; Board…
IRCCourt RulingsMar 31, 1981related by meaning
ach case employees who have not satisfied the minimum age and service requirements, if any, prescribed by the plan as a condition of participation, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary not to be discriminatory in favor of employees who are officers, s…
87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCProposed Rules (FR)Proposed May 5, 2022
…20.61
80
57,080.84
7
99,248.33
44
96,005.41
81
54,213.71
8
99,236.50
45
95,768.60
82
51,205.27
9
99,226.09
46
95,509.98
83
48,059.88
10
99,217.03
47
95,229.06
84
44,808.51
11
99,208.80
48
94,923.45
85
41,399.79
12
99,199.98
49
94,589.88
86
37,895.25
13
99,188.21
50
94,225.50
87
34,313.98
14
99,170.64
51
93,828.33
88
30…
IRCCourt RulingsDec 17, 1992related by meaning
service); cf. Devinaspre v. Commissioner, T.C. Memo. 1985-435 (employee transfer between unrelated entities constituted separation from the service). A second line of cases involves the issue of whether a person has separated from the service when the employer-corporation undergoes a change of ownership, reorganizes, …
88 FR 37424 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests IRCFinal Rules (FR)Jun 7, 2023
…20.61
80
57,080.84
7
99,248.33
44
96,005.41
81
54,213.71
8
99,236.50
45
95,768.60
82
51,205.27
9
99,226.09
46
95,509.98
83
48,059.88
10
99,217.03
47
95,229.06
84
44,808.51
11
99,208.80
48
94,923.45
85
41,399.79
12
99,199.98
49
94,589.88
86
37,895.25
13
99,188.21
50
94,225.50
87
34,313.98
( printed page 37445)
14
99,170…
IRCCourt RulingsApr 26, 2005related by meaning
es in respect of declaratory
judgments under section 7476, 64 T.C. 1177-1179 (1975).
Consistent with this legislative intent, the Court has previously held that it will not permit the administrative record to be
- 14 -
supplemented in declaratory judgment actions involving the
qualification of a retirement plan unless …
IRCCourt RulingsAug 3, 1979related by meaning
to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption.
II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
83 FR 66024 — Proposed Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCProposed Rules (FR)Proposed Dec 21, 2018
… Ongoing)
Recordkeeping (Initial setup)—122.
Recordkeeping (Ongoing)—20.
Disclosure (Initial setup)—226.25.
Disclosure (Ongoing quarterly)—131.25.
Advanced Approach (17 Institutions Affected)
Recordkeeping (Initial setup)—460.
Recordkeeping (Ongoing)—540.77.
Recordkeeping (Ongoing quarterly)—20.
Disclosure (Initial set…
IRCCourt RulingsAug 13, 1990related by meaning
Federal Rules of Civil Procedure Rule 56, upon which Rule 121 is based); Naftel v. Commissioner, supra at 529; Jacklin v. Commissioner, supra at 344. In the instant case, construing the material in a manner most favorable to respondent, we conclude that petitioners have failed to prove that there exist no genuine issu…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
rdkeeping (Ongoing)—20.
Disclosure (Initial setup)—226.25.
Disclosure (Ongoing quarterly)—131.25.
Advanced Approach
Recordkeeping (Initial setup)—460. Recordkeeping (Ongoing)—540.77.
Recordkeeping (Ongoing quarterly)—20.
Disclosure (Initial setup)—328.
Disclosure (Ongoing)—5.78.
Disclosure (Ongoing quarterly)—41.
Discl…
IRCCourt RulingsSep 30, 1991related by meaning
023.94
81,023.94
81,023.94
81,023.94
64,819.15
For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…