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101 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ree with the reasoning and the result reached by the majority. I write regarding the application of section 6654 only to clarify why the approach used in this case is consistent with our normal practice of applying the return test set forth in Beard v. Commissioner , 82 T.C. 766 (1984), affd. per curiam 793 F.2d 139 (6…
  2. 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…
  3. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019
    …ty of the underlying tax liability is at issue, we review the matter de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). A taxpayer may challenge the 4The term "Secretary" means the Secretary of the Treasury or his delegate. Sec. 7701(a)(11)(B). - 12 - [*12] unde…
  4. 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…
  5. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere 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. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  6. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  7. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …view the Commissioner's administrative determinationifor abuse of discretion. Goza v. Commissioner, 114 T.C. 3176, 181-182 (2000). In general, a taxpayer may challenge the existence or amount of an underlying tax liability if he or she did not receive a statutory notice of deficiency for such liability or did not
  8. 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…
  9. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    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…
  10. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    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…
  11. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    See Parker v. Commissioner, T.C. Memo. 2012-66, 103 T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax- (continued...) - 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to assign error to any of respondent's determinations, asserting instead that he had no…
  12. 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…
  13. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
  14. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    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 :…
  15. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  16. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  17. Notice 2024-3 — 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans
    IRCNoticesJan 8, 2024
    … from defined contribution plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. These regulations are proposed to apply only on or after the date of publication of final regulations. The proposed regulations provide that, until the final regulations are published, an e…
  18. Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans
    IRCNoticesJun 1, 2026
    … RMDs from defined benefit plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the amendments made by sections 114…
  19. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
  20. Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24…
    IRCNoticesJun 1, 2026
    … RMDs from defined benefit plans that reflects the amendments made to section 401(a)(9) by sections 114 and 401 of the SECURE Act. Under the proposed regulations, until the applicability date of the final regulations, an employer may rely on a good faith, reasonable interpretation of the amendments made by sections 114…