IRCCourt RulingsJul 8, 2019
…214,333 and an accuracy-related penalty under
SERVED Jul 08 2019
- 2 -
[*2] section 6662(a)¹ of $42,867. After concessions by the parties,2 the only issue
remaining for decision is whether petitioner received a taxable distribution from
an individual retirement account (IRA) in 2014.
FINDINGS OF FACT
Some of the facts …
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
IRCCourt RulingsJun 11, 1996related by meaning
72(t)(2)(A) provides that
the 10-percent additional tax does not apply to distributions
that are: (1) Made on or after the date on which the taxpayer attains age 59-1/2; (2) made to a beneficiary (or to the estate
of the taxpayer) on or after the death of the taxpayer; (3)
attributable to the taxpayer's being disabled…
IRCCourt RulingsApr 30, 1965
…usiness, the number of participating employees is reduced to one. Cf. Marjorie F. Birnie, 12 T.C.M. 867, where the pivotal issue was whether the remaining beneficiary of the trust was a “supervisory employee.” But a one-employee plan where the beneficiary falls within one of the four categories in whose favor the plan …
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-50 Rev. Rul. 2007-50
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2007.
T.D. 9329 T.D. 9329
Final regulations under sect…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
…istration's (SBA's) definition of small entities for RFA purposes. Of these, the OCC estimates that 867 banks originate mortgages and therefore may be impacted by this final rule.
The OCC classifies the economic impact of total costs on a bank as significant if the total costs in a single year are greater than 5 percen…
IRCCourt RulingsOct 8, 2003related by meaning
ng this amount. Subsequently,
J.D. merged into Clarkston pursuant to section 368, and filed a
final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the
final return year of J.D. eliminated by book entry as a result of
the merger.
- 5 -
Discussion
Respondent’s …
78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal IRCProposed Rules (FR)Proposed Aug 8, 2013
…ently originating one- to four-family residential mortgage loans that could be HPMLs. Approximately 867 OCC supervised banks are small entities based on the SBA's definition of small entities for RFA purposes. Of these, the OCC estimates that 428 banks originate mortgages and therefore may be impacted by the proposed r…
IRCCourt RulingsAug 8, 2005related by meaning
Commissioner
, 83 T.C.
755, 791 n.28 (1984); Kahler v. Commissioner
, 18 T.C. 31, 34-35
(1952); Roberts v. Commissioner
, T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not
subject to substantial limitations, and petitioner makes no
contention otherwise. Consequently, we find…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
…fit Computation (at death of employee in the line of duty)
Total/month: $4,667.00
Federal/month: $1,867.00
Federal percentage = federal/month
÷ Total/month: 0.400043
COLA Computation
District and Federal COLA rate 4.5%:
Total COLA: $210.00
New total benefit/month: $4,877.00
New federal benefit/month = New total benefit…
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…0
63
7,511,000
2012
Plans 94,000
119
1
63
5,911,000
Non-Complex Service Providers
700
3
119
13
63
867,000
Complex Service Providers
100
24
119
80
63
626,000
Total for 2011
61,539,000
Total for 2012
7,404,000
Note:
The displayed numbers are rounded to the nearest thousand and therefore may not add up to the totals.
…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023
…Id.
at 134.
Back to Citation
22.
Real Alternatives
v.
Sec'y of HHS,
150 F. Supp. 3d 419,
affirmed
867 F. 3d 338 (3d Cir. 2017).
Back to Citation
23.
Id.
at 349.
Back to Citation
24.
Id.
at 350.
Back to Citation
25.
82 FR 47856-47857.
Back to Citation
26.
83 FR 57627.
Back to Citation
27.
Nine other states late…
IRCCourt RulingsSep 18, 1996related by meaning
not carry her burden of proof
in respect of that adjustment or the correlative adjustments
under secs. 72(t), 4980A. Accordingly, petitioners are not liable for any increase in tax (whether under secs. 1, 72(t), or
4980A) attributable to the $103 adjustment related to additional
income from Maryland State Retirement S…
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 …
PBGCFinal Rules (FR)Jul 12, 2021
… in part 4262 is $1,946,600 ($1,800,000 + $117,600 + $22,667 + $6,333), which means approximately 4,867 contract hours assuming an average hourly rate of $400 for work done by outside actuaries and attorneys. The actual hour burden and cost burden per plan will vary depending on plan size and other factors.
The estimat…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
g a portion of the claimed rebates. As respects the claim of the Georgia company the petitioner is before us as successor in interest of that company. The petitioner and the Georgia and Mississippi companies each held certificates of necessity covering emergency facilities and claimed amortization deductions with respe…
82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…
v.
Burwell,
128 F. Supp. 3d 116 (D.D.C. 2015);
Real Alternatives,
150 F. Supp. 3d 419,
affirmed by
867 F.3d 338 (3d Cir. 2017). In another case, the plaintiff-employees work for a State government entity that the employees claim is willing, under State law, to provide a plan omitting contraception consistent with the …
IRCCourt RulingsMar 12, 2008related by meaning
ified retirement plan during
2002, before he had attained age 59-1/2 . Thus, even if the
additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c),
a point we do not decide, there is ample evidence in the record
to satisfy any burden of production imp…