IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
IRCCourt RulingsJul 13, 1995
…usually occur where the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C.
IRCCourt RulingsMar 27, 1989related by meaning
983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
IRCCourt RulingsDec 24, 1985related by meaning
y meaningful "binding obligation” could have been entered into between petitioner and Charter which would have any controlling effect in the premises. So far as respondent’s reliance on Rev. Rui. 73-124 is concerned, we note that revenue rulings do not have the force of law and are merely statements of the 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…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
86 FR 51488 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Sep 15, 2021
…74,999
87,694,622.39
176,481
103,113,327.32
Welfare:
Large Plans
108,142
111,593,190.83
9,953
1,811,627.38
Small Plans
6,137
5,407,649.86
2,507
1,252,295.71
Total:
Large Plans
369,607
174,024,829.94
152,850
33,379,940.74
Small Plans
181,136
93,102,272.24
178,988
104,365,623.03
DFEs
37,642
8,014,192.20
21,908
4,543,173.…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…individual market enrollees are enrolled in HMO, EPO, and POS options.[192]
Therefore, an estimated 627,146 policyholders in the individual market have grandfathered plans with HMO, EPO, and POS options. It is estimated that approximately 937,010 policyholders will remain in grandfathered non-federal government employe…
IRCCourt RulingsFeb 10, 1997related by meaning
ith respect to our Opinion.
In our Opinion, we held that petitioner may not deduct in a
single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19)
months. In the Motion petitioner alleges that the Court erred in
that this holding contradicts 20 years…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
85 FR 59132 — Pension Benefit Statements-Lifetime Income Illustrations ERISAFinal Rules (FR)Sep 18, 2020
…; 12,886 during the third year.
Estimated Total Annual Burden Cost:
$497,108,843 (3-year average); $627,847,556 during the first year; $433,770,504 during the second year; and $429,708,470 during the third year.
(9) Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601
et seq.) (RFA) imposes certain r…
83 FR 614 — Definition of “Employer” Under Section 3(5) of ERISA-Association Health Plans ERISAProposed Rules (FR)Proposed Jan 5, 2018
…ncertain. Predictions of these impacts are confounded by numerous factors including: ( printed page 627)
The dynamic and in some cases unstable conditions currently prevailing in local individual and small group insurance markets under existing ACA and State rules;
A lack of data on the risk profiles of existing and po…
IRCCourt RulingsMar 31, 1970related by meaning
OPINION
Quealy, Judge:
Respondent determined a deficiency in income tax of petitioner for the taxable year September 10, 1965, to June 80, 1966, in the amount of $618.41. The sole issue for decision relates to the deductibility of a payment of $2,000 made to the widow of a former officer of Utilities Engineering & Mana…
81 FR 59581 — Savings Arrangements Established by State Political Subdivisions for Non-Governmental Employees ERISAProposed Rules (FR)Proposed Aug 30, 2016
… commissions.
Id.
Back to Citation
24.
Illinois has 2,831, Minnesota has 2,724, Pennsylvania has 2,627 and Ohio has 2,333 general-purpose political subdivisions. Note also that the District of Columbia has only one general-purpose political subdivision.
See
U.S. Census Bureau, Local Governments by Type and State: 2012…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
75 FR 27122 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Dependent Coverage of Children to Age 26 Under the Patient Protection and A… IRCFinal Rules (FR)May 13, 2010
…[24] The Department estimates that 126,000 State and local governmental plans would have to send 19,627,000 notices to eligible employees and 490 insurers in the individual market would have to send approximately 5,444,000 notices to individuals with policies covering dependents.[25]
For purposes of this estimate, the …
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…