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…
IRCCourt RulingsJul 13, 1995★ strong match
OPINION
Wright, Judge:
Respondent determined 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)…
IRCRegulationsJul 26, 2016
…2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Survivor Annuities; Two Lives—Expected Return Multiples Ages 105 106 107 108 109 110 111 112 1…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
81 FR 63414 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Sep 15, 2016
rt 4022, Rate Set 276, as set forth below, is added to the table.
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set For plans with a valuation date
Immediate
annuity rate
(percent)
Deferred annuities
(percent)
On or after
Before
i1
i2
i3
n1
n2
* * * * …
IRCCourt RulingsJul 2, 2002
…an. Respondent calculated the outstanding principal plus
interest on the Atascadero loan to be $176,276. Respondent
computed this figure by adding the principal of the Atascadero
loan, $160,701, to the $5,570 outstanding balance of Stephanie’s
1988 loan. The interest on the outstanding amount, as determined
by responde…
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
IRCCourt RulingsMar 31, 2015
…herwise have an opportunity to
dispute the liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114 T.C. 604, 609 (2000). The phrase "underlying tax liability" includes the tax deficiency,
additions to tax, and statutory interest. Katz v. Commissioner, 115 T.C. 329, 339
(2000).
In determining whether to sustain the…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…0
34,857,610
34,857,610
9
63.0
37.0
33.1
0
0
0
34,817,023
34,817,023
10
63.0
37.0
33.1
0
0
0
34,797,276
34,797,276
1
Cost estimates are not inflation adjusted and are presented in constant dollars.
I. Transfers
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024
…n average, five minutes, resulting in an hour burden of 1,737,781 hours with an equivalent cost of $114,676,201.[82] Table 5—Hour Burden and Equivalent Cost Associated Preparing and Sending Disclosures
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Clerical
1,73…
IRCCourt RulingsJul 26, 1989related by meaning
OPINION
COHEN, Judge:
Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
IRCCourt RulingsSep 24, 2007
… the Commissioner to
grant equitable relief, for abuse of discretion . Fernandez v .
Commissioner , 114 T .C . 324, 330-333 (2000) ; Butler v .
Commissioner , 114 T .C . 276, 292 (2000) .
Section 6015(b )
Section 6015(b)(1) provides for relief from liability for
tax attributable to an understatement if all five conditi…
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…
IRCCourt RulingsNov 21, 2007
…for
1998, 1999, and 2000 are summarized below :
1998 1999 200 0
Income :
1 Gross receipts or sales $114,634
2 Returns and allowances -03 Subtract line 2 from line 1 114,634
4 Cost of goods sold -05 Gross profit, subtract lin e
4 from line 3 114,634
6 Other income -07 Gross income . Add lines 5 and 6 114,63 4
Expenses :…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…active-physicians/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22.
Back to Citation
276. The burden is estimated as follows: 145,887 individual physician practitioners × 2.5 hours = 364,717 hours. A labor rate of $169.40 is used for a physician. The labor rate is applied to the following calculation: 1…
IRCCourt RulingsAug 16, 2005
…ion for redetermination of a
deficiency filed pursuant to section 6213(a). Butler v.
Commissioner
, 114 T.C. 276, 287-288 (2000). A second basis upon
which we may exercise jurisdiction is contained in section
6015(e). This provision allows a spouse who has requested relief
to petition the Commissioner’s denial of relie…
IRCCourt RulingsOct 28, 1965related by meaning
…951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually paid by him to Ada an…
IRCCourt RulingsJan 16, 2002
…itable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000).
Pursuant to the directions in the statute, respondent issued
Rev. Proc. 2000-15, 2000-5 I.R.B. 447, setting forth the.criteria
under which respondent will…
IRCCourt RulingsOct 29, 2020related by meaning
SEC
T.C. Memo. 2020-147
UNITED STATES TAX COURT
RAM RATAN SHARMA AND SHAKUNTALA SHARMA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19466-17. Filed October 29, 2020.
Ram Ratan Sharma and Shakuntala Sharma, pro sese.
Mayer Y. Silber, Elizabeth A. Carlson, and Stanislaw Balazia, for
respondent.…