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88 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …each with an equivalent cost of $7,354,578. The 3-year average cost burden for DOL and Treasury is $279,389 each. The summary of burden below encompasses the following ICRs: (1) Information to be Shared about the QPA (26 CFR 54.9816-6T(d), 29 CFR 2590.716-6(d)), (2) Complaints Process for Surprise Medical Bills (26 CFR…
  2. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    individual.5 See H. Rept. 378, 87th Cong., 1st Sess. 89 (1961), 1962-3 C.B. 261, 279-280. A Petitioner concludes that on the 'basis of the legislative history a common law employee who has self -employment earnings is treated as an owner-employee and is entitled to make retirement plan contributions and deduct those co…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    … on Sept ember 6, 1934.”); Thomas E. Jenks, “Treasury Regulations Under Section 482”, 23 Tax Lawyer 279, 279 (1970) (“The * * * regulations were issued in 1934” . ). 77 (5) “ Group” or “group of controlled taxpayers ” means the organizations, trades, or businesses owned or controlled by the same interests. (6) The term…
  4. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
  5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    ent with the intent of DEFRA, and because it permissibly fills a gap created by sections 419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is not impermissibly broader than sections 419 and 419A and, accordingly, we hold that it is valid. Chevron…
  7. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023★ strong match
    … burden of establishing the clerical or mathematical error. Raquet v. Commissioner, T.C. Memo. 1996-279, 1996 Tax Ct. Memo LEXIS 293 , at *10 . The taxpayer retain s the burden with regard to the Commissioner’s determinations. I d . at *10 – 11 ( first citing Estate of Applestein v. Commissioner, 80 T.C. 331, 347 n.5 (…
  8. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  9. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997★ strong match
    …turn paid his creditor. Douglas v. Willcuts , 296 U.S. 1 (1935); United States v. Boston & M.R.R. , 279 U.S. 732 (1929); Old Colony Trust Co. v. Commissioner , 279 U.S. 716 (1929); Wall v. United States , 164 F.2d 462 (4th Cir. - 24 - 11 We note that petitioners did not argue that the dividends exceeded the earnings an…
  10. Treas. Reg. § 1.421-1(j)(2) — Meaning and use of certain terms.
    IRCRegulationsSep 9, 2016
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  11. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  12. Treas. Reg. § 1.421-2(f) — General rules.
    IRCRegulationsJan 19, 2017
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  13. Treas. Reg. § 1.422-5(f)(2) — Permissible provisions.
    IRCRegulationsSep 9, 2016
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  14. Treas. Reg. § 1.424-1(g)(2) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  15. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  16. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …stimates that the cost burden for preparing and mailing the notices will be approximately equal to $279, that is, 410 * ((2 * $0.05) + $0.58) = $279 (rounded). Therefore, the total cost associated with this requirement is (8* legal professional labor rate of $140.96) + (13.7* clerical labor rate $55.23) + $279 = $2,180…
  17. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …issioner, T.C. Memo. 2008-262, 96 T.C.M. (CCH) 354, 357 ; cf . Old Colony Tr . Co. v. Commissioner, 279 U.S. 716, 729 (1929) (“ [D]ischarge by a third person of an obligation to [the taxpayer] is equivalent to receipt by the person taxed.”). More specifically, IRA funds constitute gross income as an involuntary distrib…
  18. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002related by meaning
    stribution should not be subject to the 10-percent additional tax because she is entitled to rely on the advice of respondent’s representatives. - 7 - Although we cannot be certain whether petitioner misunderstood the advice she received or whether erroneous advice was rendered, that distinction does not make a differe…
  19. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    tomatic retroactive disqualification for operational errors is a “Draconian approach” that is not sanctioned by either the statute or the regulations. Respondent argues, however, that section 415 places restrictions on employers’ deductions for contributions to employee plans because deferred compensation plans are sub…
  20. 81 FR 91032 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Dec 16, 2016
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 279, as set forth below, is added to the table. Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments * * * * * ( printed page 91033) Rate set For plans with a valuation date Immediate annuity rate (percent) …