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1. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
   IRCCourt RulingsMar 31, 1997
   …o the salary he would normally receive when the vacation is actually taken. B. Petitioner's Section 463 Deductions For the General Plan and the Acme Markets Plans, petitioner included both the unused yearend vested and nonvested vacation benefits in calculating its vacation pay accruals under section 463 for the releva…
2. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
   IRCProposed Rules (FR)Proposed Aug 3, 2023
   ger) + (33,076 self-funded, non-Federal governmental health plans × 4 NQTLs × 2 hours × $109.96 for a business operations specialist)] = $291,031,092. Back to Citation 257.  A labor rate of $132.38 is used for a general or operations manager and a labor rate of $109.96 is used for a business operations specialist. The …
3. 82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
   IRCFinal Rules (FR)Oct 13, 2017
   …on to participants and beneficiaries as soon as practicable. As discussed above, HHS estimates that 109 entities that are using the accommodation process will revoke their use of the accommodation, and will therefore be required to cause the notification to be sent (the issuer or third party administrator can send the …
4. PLR 199934002 — Deferred Compensation
   IRCPrivate Letter RulingsAug 27, 1999
   …ake their vacations. In American Stores , the petitioner accrued and deducted, under former section 463 of the Code, all vacation benefits that it expected to pay within 8 months after the close of its taxable year ending January 30, 1988. Prior to its repeal, section 463 permitted taxpayers to elect to establish a res…
5. 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…
6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …Motor Vehicle M frs. Ass’n of the U .S. , Inc. v. State Farm Mut . Auto . Ins . Co . (State Farm) , 463 U.S. 29, 34, 37 (1983), the Supreme Court held that the Department of Transportation failed to present an “adequate basis and explanation” for rescinding its regulatory requirement that car manufacturers equip cars w…
7. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
   IRCCourt RulingsAug 24, 1995related by meaning
   OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
8. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
   IRCCourt RulingsJul 24, 2003related by meaning
   …riguez , for respondent. COUVILLION, Special Trial Judge : This case was heard pursuant to section 7463 in effect when the petition was filed. 1 The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. Respondent determined a deficiency of $1,669 in petitioners…
9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
10. Treas. Reg. § 1.404(b)-1T — Method or arrangement of contributions, etc., deferring the receipt of compensation or providing for deferred benefits. (Temporary)
    IRCRegulationsMay 18, 2016
    …ter July 18, 1984, in taxable years of employers (and payors) ending after that date. Also, section 463 shall govern the deduction of vacation pay by a taxpayer that has elected the application of such section. For rules relating to the deduction of contributions paid or accrued with respect to a welfare benefit fund, …
11. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    …ermined a deficiency in petitioner’s Federal income tax for taxable year 1990 in the amount of $239,463. After concessions by the parties, the issues for our consideration are as follows: (1) Whether dividends paid to an employee stock ownership plan, deductible under section 404(k), are deductible under section 56(g)(…
12. Treas. Reg. § 1.436-1(d)(3)(v) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …5, the plan administrator determines that the unrestricted portion of Participant R's benefit is $1,463 per month, payable from age 55 to age 62 ($600 + .590 × $1,463 = $1,463 payable until age 62; $1,463−$1,463 = zero payable after age 62).(vi) Combining the unrestricted and restricted portions of the benefit, Partici…
13. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
14. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    the deduction would frustrate a sharply defined Federal or State policy. Wood v. United States , 863 F.2d 417 (5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir. 1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v. Commissioner , 69 T.C. 114 (1977). The test of nondeductibility is the severity and imme…
15. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
16. Treas. Reg. § 1.404(a)-1T — Questions and answers relating to deductibility of deferred compensation and deferred benefits for employees. (Temporary)
    IRCRegulationsMay 18, 2016
    …ter July 18, 1984, in taxable years of employers (and payors) ending after that date. Also, section 463 shall govern the deduction of vacation pay by a taxpayer that has elected the application of such section. For rules relating to the deduction of contributions paid or accured with respect to a welfare benefit fund, …
17. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    IRCCourt RulingsJun 6, 2005related by meaning
    … the circumstances of inclusion, deductions, and exceptions. See Wilkins v. Commissioner , 120 T.C. 109, 112 (2003). The 10-percent additional tax applies to early distributions unless otherwise specifically exempted. Roundy v. Commissioner , 122 F.3d 835, 837 (9th Cir. 1997), affg. T.C. Memo. 1995-298. Accordingly, re…
18. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    air market value of a share of the stock is $109.50. The remuneration resulting from the vesting of the restricted stock is $109,500 ($109.50 × 1000). (ii) The $109,500 of remuneration is attributed to services performed by F over the 1,095 days between January 1, 2017 and December 31, 2019 (365 days per year for the 2…
19. 83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Nov 15, 2018
    …ided by HHS or substantially similar language. As mentioned, HHS is anticipating that approximately 109 entities will use the optional accommodation (100 that used it previously, and 9 that will newly opt into it). It is unknown how many issuers or third party administrators provide health insurance coverage or service…
20. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    itioner can show that he comes within one of the exceptions of section 6654(e). Hudson v. Commissioner , 103 T.C. 90, 110 (1994), affd. without - 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears the burden of proof on this issue, Baldwin v. Commissioner , 84 T.C. 859, 871 (1985), and the record cont…