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80 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2019-83 — Nancy Burack v. Commissioner
    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 …
  2. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    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…
  3. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    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…
  4. 44 T.C. 137 — Greenwald v. Commissioner
    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 …
  5. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    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…
  6. 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…
  7. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  8. 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…
  9. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    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 …
  10. 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…
  11. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    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…
  12. 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…
  13. 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. …
  14. 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…
  15. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    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…
  16. 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 …
  17. 86 FR 36598 — Special Financial Assistance by PBGC
    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…
  18. 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…
  19. 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 …
  20. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    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…