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99 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 54.9815-1251(g)(5) — Preservation of right to maintain existing coverage.
    IRCRegulationsJan 14, 2021
    …al inflation (as defined in paragraph (g)(4)(i) of this section) from March 2010 is 0.2269 (475−387.142 = 87.858; 87.858 ÷ 387.142 = 0.2269). The maximum percentage increase permitted is 37.69% (0.2269 = 22.69%; 22.69% + 15% = 37.69%). Because 33.33% does not exceed 37.69%, the change in the copayment requirement at th…
  2. 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…
  3. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …,085. HHS assumes that 80 percent of individual physician practitioners have a website resulting in 116,709 websites needed to be updated with good faith estimate notices. HHS assumes that the physician will pay a computer programmer to make the website update. The burden is estimated as follows: 116,709 websites needi…
  4. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005
    …s. On their joint Federal income tax return for 2000, petitioners reported as gross income the $115,142.97 in distributions from their qualified plans. Petitioners included with their 2000 tax return Form 5329, Additional Taxes Attributable to IRAs, Other Qualified Retirement Plans, Annuities, Modified Endowment Contra…
  5. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014★ strong match
    …spect to any penalty, including the accuracy-related penalty. Sec. 7491(c); Hiebee v. Commissioner, 116 T.C. 438, 446 (2001). To meet that burden, the Commissioner must come forward with sufficient evidence indicating that it is appropriate to impose the relevant penalty. Hiebee v. Commissioner, 116 T.C. at 446. Howeve…
  6. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017★ strong match
    is appropriate. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the Commissioner's penalty determination is incorrect. See Rule 142(a); Welch v. Helvering, 290 U.S. 111, …
  7. T.C. Memo. 2017-178 — Dean Russell Cates & Teresa Stinnett Cates v. Commissioner
    IRCCourt RulingsSep 13, 2017
    bee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the Commissioner's penalty determination is incorrect. S_e_e Rule 142(a); Welch v. Helvering, 290 U.S. at 115; Higbee v. Commissioner, 116 T.C.…
  8. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975); …
  9. 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…
  10. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  11. 77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Feb 3, 2012
    … 286,000 Investment Disclosure 8,929,000 1,210,000 1,210,000 3,783,000 Update Investment Disclosure 116,000 116,000 116,000 116,000 Investment Disclosure Total 9,045,000 1,326,000 1,326,000 3,899,000
  12. 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…
  13. Rev. Rul. 2021-3 — Section 401. —Qualified Pension, Profit-Sharing, and Stock Bonus Plans
    IRCRevenue RulingsFeb 1, 2021
    …1960 2027 104,928 1961 2028 107,364 1962 2029 109,704 1963 2030 112,044 1964 2031 114,324 1965 2032 116,544 1966 2033 118,668 1967 2034 120,672 1968 2035 122,580 1969 2036 124,356 1970 2037 126,012 1971 2038 127,608 1972 2039 129,180 1973 2040 130,680 1974 2041 132,072 1975 2042 133,368 1976 2043 134,532 1977 2044 135,…
  14. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    …tion because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984)). Accordingly, in order to give effect to our disposition of the disputed issue, as well as respondent's concession, an…
  15. Notice 2022-45 — Notice 2022-45 extends the deadlines for amending an eligible retirement plan (including an individual retirement arrangement or annuity contract) to reflect t…
    IRCNoticesOct 17, 2022
    …t the provisions of section 2202 of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136, 134 Stat. 281 (2020) (CARES Act), and section 302 of Title III of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub…
  16. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  17. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015
    …3001(c), 112 Stat. at 727, and the taxpayer in that case anyway bore the burden of proof under Rule 142(a), see Matthews v. Commissioner, 92 T.C. at 361-362 (citing Rule 142(a), and Welch v. Helvering, 290 U.S. 111, 115 (1933)). Moreover, none of the recent cases that relied on Bunney cited or discussed the applicabili…
  18. T.C. Summary Opinion 2006-177 — Richard D. Smart v. Commissioner
    IRCCourt RulingsOct 25, 2006
    return, petitioner properly reported the $116,251 .20 distribution as income but did not report the 10-percent additional tax for early distributions under section 72(t) . In the notice of deficiency, respondent determined that petitioner was liable for the 10-percent additional tax on the early $116,251 .20 distribut…
  19. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  20. T.C. Summary Opinion 2016-52 — Bruce W. Peterson & Lisa A. Peterson v. Commissioner
    IRCCourt RulingsSep 1, 2016
    …, the Commissioner bears the burden of production with regard to penalties. Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner has met the burden of production, the taxpayer has the burden of proving that the penalties are 9Petitioner's annuity contract was a qualified individual retirement annuity…