IRCCourt RulingsApr 25, 2011
…ll-time employment.
When petitioner retired in 2005, she had two outstanding
loans of $7,872 and $3,624 from her Fe eral Employees' Thrift
Savings Plan (TSP) account. On or about February 25, 2005, the
TSP sent petitioner two letters regard ng her loans . The letters
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informed petitioner that if she did not repay …
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation
52.
5 U.S.C. 601
et seq.
Back to Citation
53.
5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551.
Back to Citation
54.
Public Law 104-4, 109 Stat. 48 (Ma…
IRCProposed Rules (FR)Proposed Oct 14, 2016related by meaning
a statute or court order, to liquidate the entry within 90 days from when the suspension is removed, CBP is proposing to remove section 159.12(f)(2). Section 173.4a provides for the correction of clerical errors prior to liquidation. The section implements section 520 of the Tariff Act of 1930, as amended (19 U.S.C. 1…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…528,299 33,986 30,726 31,975 9,364
Advertising,
Inc.
Greenstone 3,695 5,828 8,216 9,044 800 955 518 624
Roberts Adv.
Inter- 1,152,870 1,218,141 1,329,488 1,634,670 132,570 143,614 155,625 187,486
public
Group
of Cos.
Laser N/A N/A 2,483 1,274 N/A N/A (96) (199)
Vision
Centers,
Inc.
Omnicom 881,286 1,007,173 1,178,233 1…
IRCCourt RulingsJan 5, 2017related by meaning
ccuracy-related penalty under
section 6662.
OPINION
I. Preliminary Matters
Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree.
Generally, the Commissioner's determinations in a notice of deficiency are
presumed correct…
IRCCourt RulingsFeb 9, 2023
… indicates an intent to
incorporate existing judicial interpretations. Bragdon v. Abbott , 524
U.S. 624, 645 (1998). In First Security Bank , and as further explained in
Basye, the Supreme Court held that blocked income cannot be allocated
to someone who has not received it and is legally barred from receiving
it. As n…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
…9 8,844
1990 35,374 -0- 7,959 6,721
1991 35,374 -0- 7,959 4,599
1992 35,374 -0- 7,959 2,476
1993 21,624 $707,488 65,620 7,291
After concessions, the issues for decision are:
1. Whether petitioners are disqualified persons as
described in section 4975(e)(2). We hold that they are, and that
they are jointly and severally…
IRCCourt RulingsJul 24, 1996
… of $9,022,227 for incurred but
unpaid medical, dental, and short-term disability benefits and
$353,624 for administrative expenses, none of which are at issue
in this case. Respondent has conceded that petitioner is
entitled to a deduction in the amount of $125,465 for additional
administrative expenses. The amount of…
IRCCourt RulingsDec 22, 2008related by meaning
foregoing quoted terms are specially defined and used
under the "Public Salary Tax Act of 1939" ;
3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor
"taxpayer," nor "non-resident alien," nor any other
"legal entity" "made liable for" or "subject to" any
"internal reve…
Notice 2026-9 — This notice provides guidance relating to amendments under section 501 of the SECURE 2.0 Act of 2022 for individual retirement arrangements and annuities (IRAs… IRCNoticesFeb 9, 2026related by meaning
igibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restri…
IRCCourt RulingsAug 22, 1994
…0,836
Total receipts 28,492,085 44,667,010 44,355,535
Disbursements:
Benefit payments 40,711,951 44,624,024 45,382,893
Expenses 147,753 72,543 167,565
Total disbursements 40,859,704 44,696,567 45,550,458
Net increase (decrease) of assets (12,367,619) (29,557) (1,194,923)
Assets at end of period 1,967,062 1,937,506 742,…
IRCCourt RulingsMar 31, 1961
…king two minor adjustments, determined that for 1951 Kimble Glass’ income tax net income was $2,098,624.27, that its excess profits net income was $2,095,559.84, and that the excess profits credit was $1,609,527.92. This resulted in a deficiency of $143,884.02 for 1951 and the disallowance of the tentative refund of $2…
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…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…
1,307,700
167.48
219,013,596
Plan MEWAs that are not fully insured
132
15
60
118,800
167.48
19,896,624
Non-plan MEWAs that are not fully insured
21
15
60
18,900
167.48
3,165,372
First-year Total
10,021
15
5,877,000
984,279,960
Subsequent Years
Issuers (health insurance company/State combinations)
1,467
15
12
264,060
1…
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…
IRCCourt RulingsJun 5, 2014related by meaning
vit from Chicago Title in which the company admitted fault for the error.
Mr. Dabney sold the Brian's Head property and received $127,226 on the sale, after taxes and fees. That amount was wired directly into the Charles Schwab IRA
- 6 -
[*6] on or around January 28, 2011. Mr. Dabney marked the deposit as a rollover
co…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…