IRCCourt RulingsFeb 9, 2023★ strong match
…il,
3M Company, and 3M IPC for the 2006 year is $165,783 (equal to
$4,283,153 minus an offset of $4,117,370 for unreimbursed research -
and -develop ment expenses (R & D offset )) . We interpret the term
“minimum section 482 adjustment” to be the minimum section 482
adjustment that would be made if petitioner were to p…
IRCCourt RulingsJul 14, 2005★ strong match
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…
IRCFinal Rules (FR)Sep 16, 2025
…al participates in a SIMPLE plan to which the higher applicable dollar catch-up limit under section 117 of the SECURE 2.0 Act applies, commenters requested that the final regulations clarify whether the SIMPLE plan may provide that the applicable dollar catch-up limit that applies to the individual is an amount equal t…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
… $5,000 of compensation for the preceding year and the required notifications to employees. Section 117 of the SECURE 2.0 Act amends sections 408(p), 401(k)(11), and 414(v) of the Code to increase both the annual salary reduction contribution/elective contribution limit and the limit on additional catch-up contribution…
IRCProposed Rules (FR)Proposed Jan 13, 2025
…uirements for certain catch-up eligible participants pursuant
( printed page 2646)
to sections 109, 117, and 603 of Division T of the Consolidated Appropriations Act, 2023, Public Law 117-328, 136 Stat. 4459 (2022), known as the SECURE 2.0 Act of 2022 (SECURE 2.0 Act).
This document also proposes conforming amendments …
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…
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…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsDec 18, 2012
…is treatment, the respective deficiencies are $108,656, $67,059, $126,860, $121,404, $154,258, and $117,884.
We decide the following issues:4
1. whether petitioners' gross income for the subject years includes
nonemployee compensation of $483,591, $487,873, $536,145, $628,500,
$694,986, and $815,963, respectively, that…
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…
IRCCourt RulingsFeb 15, 2002
…ioner had a savings account with Hibernia
National Bank. That account generated interest income of $117
that petitioner did not withdraw during the year.
Petitioner obtained extensions of time within which to file
his 1998 Federal income tax return to October 15, 1999. He did
not file his 1998 return until October 19, …
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…
IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…s)
3,552 Service Providers
1
$181.06
3,552
$643,125
Explanation Preparation (In-House)
77,012 = 770,117 Plans × 10% Not Using a Service Provider
1
181.06
77,012
13,943,731
Adding Contact and Plan Information to Drafted Explanations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019
…rtunities under Section 701(f)(3)(B)(i)(l)—each employee a separate violation
29 CFR 2575.1-3
$114
$117.
EBSA
Employee Retirement Income Security Act
Section 502(c)(9)(B)—Per day for each failure by a plan to timely provide to any State information required to be disclosed under Section 701(f)(3)(B)(ii), as added by CH…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…01 hours annually and the total cost, including printing and materials cost, will be approximately $117,228,780 annually starting in 2022. For all consumers, the total annual burden to read and understand the notice will be 1,830,424 hours with an equivalent cost of $99,099,147 starting in 2022.
Table 9—One-Time and An…
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
.
IRCProposed Rules (FR)Proposed Nov 27, 2019
…r three years, would be 1,247,230 hours with an average annual associated equivalent total cost of $117,507,376.
TABLE 12—Estimated Three Year Average Annual Hour Burden and Costs for All Issuers and TPAs To Develop and Maintain the In-Network Providers Negotiated Rate File
Year
Estimated
number of health
insurance iss…
IRCCourt RulingsDec 16, 1971
…s a fellowship grant,
including the value of contributed services and accommodations ; * * * Sec. 1.117-4 Items not considered as scholarships or fellowship grants.
The following payments or aRowances shall not be considered to be amounts received as a scholarship or a fellowship grant for the purpose of section 117 :
…