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61. 77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Feb 3, 2012
    …,248,000 23,690,000 8,471,000 1,209,000 40,619,000 2014 6,774,000 22,140,000 7,917,000 1,130,000 37,962,000 2015 6,331,000 20,692,000
62. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …ar Deficiency sec. 6662(a) 2000 $346,079 $69,216 2001 338,436 67,088 2002 2,875,116 575,023 2003 12,962,223 2,592,445 2004 3,567,442 713,488 With respect to petitioners Estate of Arthur E. Kechijian and Susan P. Kechijian, the IRS determined deficiencies and accuracy-related penalties as follows: Penalty Year Deficienc…
63. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …,521 764,275 73,019,796 (50,720) 6/30/86 81,916,703 829,481 82,746,184 1,752,870 6/30/87 94,305,548 962,317 95,267,865 4,098,466 6/30/88 112,993,217 1,725,585 114,718,802 6,871,287 6/30/89 143,612,396 4,476,187 147,088,583 9,650,154 6/30/90 159,302,147 2,822,959 162,125,106 11,430,723 6/30/91 149,671,091 2,045,944 151,…
64. T.D. 9220 — Temporary and proposed regulations under section 408A of the Code provide guidance concerning the tax consequences of converting a non-Roth IRA annuity to a Ro…
    IRCTreasury DecisionsSep 26, 2005
    … that distributions are being made to satisfy section 401(a)(9). Rev. Proc. 2005-25, 2005-17 I.R.B. 962, provides safe harbor formulas that, if used to determine the value of a life insurance contact, retirement income contract, endowment contract, or other contract providing life insurance protection that is distribut…
65. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …ndent ultimately concedes or loses a case is not determinative. See Wasie v. Commissioner , 86 T.C. 962, 968-969 (1986); DeVenney v. Commissioner , 85 T.C. 927, 930 (1985). 2. Net Worth Respondent contends that petitioners have failed to demonstrate that they satisfied the net worth requirement of section 7430(c)(4)(A)…
66. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    if any, the distributions they were deemed to have received from * * * [the S Corporation] exceeded - their bases in * * * [the S corporation]. - 32 - However, in Hellweg, the Commissioner made no such adjustments We stated that because the Còmmissioner made no section 482 ädjustment which would result in distributiöns…
67. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …1983, Machise/Intercoastal accrued, and deducted for Federal income tax purposes, "rents" of $2,061,962. For the two periods, these amounts totaled $3,530,792, which is 115 percent of the $3,070,253 17 paid by MIT 83 for payroll and independent contractor costs. - 55 - Respondent has issued statutory notices of deficie…
68. 100 T.C. 216; 100 T.C. No. 15 — Halliburton Co. v. Commissioner
    IRCCourt RulingsMar 24, 1993related by meaning
    the allocation of forfeitures among remaining participants resulted in prohibited discrimination in favor of highly compensated employees. Discussion Before turning to the merits of the parties’ contentions, we note preliminarily that respondent bears the burden of proof herein because respondent failed to issue a fin…
69. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
70. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987
    … States, 572 F. Supp. 9 (E.D. Ark. 1982), affd. 718 F.2d 290 (8th Cir. 1983), cert. denied 466 U.S. 962 (1984). Respondent’s regulation recognizes the continuing incidence of the act of self-dealing concerning the leasing of property or, as applicable here, the continuing incidence of the prohibited transaction concern…
71. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
    IRCCourt RulingsSep 19, 1978related by meaning
    dent’s action, at least as to 1970, 1971, and 1973. Cf. Christian Echoes National Ministry, Inc. v. United States, 470 F.2d 849, 858 (10th Cir. 1972). In Ryan School, Sherwood Swan, and Lansons, neither the character of the taxpayer’s business nor the essential composition of its work force changed. In short, these cas…
72. T.C. Memo. 2022-3 — John M. Larson v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …er ( Austin II ) , T.C. Memo. 2017-69, at *33 , aff’d sub nom. Estate of Kechijian v. Commissioner, 962 F . 3d 800 (4 th Cir. 2020) . To address concerns about ownership structures involving S corporations and ESOPs, Congress amended the Internal Revenue Code in 2001 to require that income or loss that had previously b…
73. 67 T.C. 906 — Jennemann v. Commissioner
    IRCCourt RulingsMar 7, 1977related by meaning
    the entire distribution in excess of personal contributions was required to be treated as ordinary income under section 402(a)(2) as it read in 1971. Petitioner does not argue that respondent misread the statute. Instead, he raises constitutional objections to our power to decide the case and to congressional power to…
74. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
    IRCCourt RulingsMay 17, 1973related by meaning
    was “earned income” within the ambit of section 911 (b) and is excludable from gross income to the extent of $25,000 per year under section 911 ('a). Petitioner has claimed overpayments of $5,517 for 1965 and $7,040.82 for 1966. As to the first amount, it is stipulated that the petitioner overstated his gross income f…
75. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …rm autos. _0 $169,519 1,566 $189,419 Expenses Compensation of petitioners. 122,400 139,200 Taxes. 1,962 2,677 Interest. 0 29 Depreciation. 3,674 4,611 Pension and profit-sharing contributions. 30,600 35,500 Other deductions. 3,847 (162,483) 5,626 (187,643) Taxable income. . 7,036 1,776 Tax. . 1,114 273
76. 69 T.C. 1055; 1 Employee Benefits Cas. (BNA) 1610 — Kiddie v. Commissioner
    IRCCourt RulingsMar 30, 1978
    …deficiencies in petitioner’s Federal corporate income taxes: Taxable year Deficiency 1971 .... ..$7,962.31 1972 .... ..16,972.52 1973 .... ...4,613.50 Due to concessions made by the parties the sole issue remaining for our determination is whether petitioner’s 1972 and 1973 contributions to its pension plan are deducti…
77. 69 T.C. 750 — Orzechowski v. Commissioner
    IRCCourt RulingsFeb 22, 1978related by meaning
    g the petitioner’s contention, we conclude and hold that the petitioner’s contribution was an excess contribution to which section 4973 is applicable. Decision will be entered for the respondent. Reviewed by the Court. All statutory references are to the Internal Revenue Code of 1954, as in effect during the year in is…
78. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …te Lost Earnings 909 1 909 140.32 127,551 Clerical staff gather information 909 2.5 2,273 65.99 149,962 Clerical staff maintain recordkeeping 909 1 909 65.99 59,985 Total 1,237 5,648 465,963 The Department estimates that external service providers will spend about 10 minutes completing and submitting the online SCC not…
79. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
80. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …a Cashout Avoidance: Rule $5,334 $5,202 $5,086 $5,007 $4,967 $4,926 $4,886 $4,865 $4,844 $4,844 $49,962 −Baseline 5,461 5,461 5,461 5,461 5,461 5,461 5,461 5,461 5,461 5,461 54,609 = Assets Retained 127 259 375 454 494 534 575 596 617 617 4,647 Present Value of Assets Retained by Discount Rate: 3 Percent 123 244 343 40…