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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
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 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…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…61,709
311,665
1,773,374
1,722,728
1,722,728
Remain in Plan:
Number of Accounts
2,036,212
363,609
2,399,821
2,399,821
2,399,821
Rollover:
Number of Accounts
1,350,202
190,462
1,540,664
1,591,310
1,591,310
× Estimated Percent of Rollovers Going into Default IRAs
60%
0%
60%
60%
Total Default IRAs
810,122
0
810,122
954,78…
IRCCourt RulingsFeb 9, 2023★ strong match
…ence introduction to the case, id.
at 394 & n.1 and then described the relevant facts , id. at 396- 399. The
opinion then descri bed r espondent’s position as follows:
Pursuant to his § 482 power to allocate gross income among
controlled corporations in order to reflect the actual
incomes of the companies, the Commissi…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
… and Credit Unions
2,853
0.23
0.25
223
82
FDIC
2,571
0.14
0.25
93
Board 224
418
0.18
0.25
19
OCC
1,399
0.16
0.25
55
NCUA
2,437
0.07
0.25
44
Total
9,810
416
Investigate and Verify Requirement for Additional Written Appraisal
Bureau
Depository Inst. > $10 B in total assets+
Depository Inst. Affiliates
132
20.05
0.25
662…
78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal IRCProposed Rules (FR)Proposed Aug 8, 2013
…,853
0.23
0.25
159
82
FDIC
2,571
0.
0.25
93
Board 160
418
0.18
0.25
19
( printed page 48584)
OCC
1,399
0.16
0.25
55
NCUA
2,437
0.07
0.25
44
Total
9,810
416
Investigate and Verify Requirement for Additional Written Appraisal
Bureau:
Depository Inst. > $10 B in total assets + Depository Inst. Affiliates
132
20.05
0.25
6…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
5,692
5,785
§ 100.4(c) introductory text
68,300
69,417
§ 100.5(c)
7,399
7,520
§ 100.5(d)
313
318
§ 100.5(e)
250,433
254,530
( printed page 5384)
Note: The following Appendix will not appear in the Code of Federal Regulations.
Agency
Law
Name/description
CFR citation
2016
2017
Min penalty (rounded to nearest dollar)
Max…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…R 13592), by the inflation adjustment factor for 2007 of 1.13833, which resulted in a penalty of $7,399. The inflation-adjusted amount of $899 is less than the statutory catch-up adjustment cap of a 150 percent increase of the $7,500 penalty in effect as of November 2, 2015, which is $11,250. Therefore, the daily penal…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
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 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…
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 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 :…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsNov 10, 1998
…at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
T.C. Memo. 1998-399
UNITED STATES TAX COURT
RONNY H. AND CHARLOTTE A. SCHMALZER, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21473-95. Filed November 10, 1998.
Ronny H. and Charlotte A. Schmalzer, pro se.
Rob…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…