IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
IRCCourt RulingsFeb 9, 2023
… 1959)
In Commissioner v. First Sec . Bank , 405 U.S. at 396, a holding
company
122
owned two banks
123
and an insurance company.
124
Customers of the two banks sometimes wanted to buy credit-life
insurance; the banks would refer these customers to an unrelated
insurance company that had agreed to reinsure the referred…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…rporated into ERISA section 715 and Code section 9815, for renewals, reissuances and reenrollments.[123]
IRCCourt RulingsJul 22, 1980
…ion to its profit-sharing trust. In his notice of deficiency, respondent disallowed the claimed $16,123 deduction and explained that— (a)(1) The deduction claimed for contributions to your profit-sharing plan for the taxable year ended December 31, 1974 in the amount of $16,123.00 is not allowed because it has been det…
IRCCourt RulingsApr 2, 2020
…ans that the Court considers evidence not in the
administrative record.3 Robinette v. Commissioner, 123 T.C. at 101.
In a Tax Court proceeding, the taxpayer has the burden of proof. Rule
142(a).
We now explain the procedural history of this case relevant to determining
what issues are properly before the Court.4
Goldbe…
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…
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…ndividual Health Insurance Coverage (26 CFR 54.9802-4(c)(5), 29 CFR 2590.702-2(c)(5) and 45 CFR 146.123(c)(5)); and (2) HRA Notice to Participants (26 CFR 54.9802-4(c)(6), 29 CFR 2590.702-2(c)(6) and 45 CFR 146.123(c)(6)). A third IC is sponsored solely by DOL (29 CFR 2510.3-1): (3) Notice to Participants that Individu…
IRCCourt RulingsJun 25, 2012
…es and that she meets the net worth requirements.
See Rule 232(e); see also Corson v. Commissioner, 123 T.C. 202, 206 (2004).
The Commissioner must show that his position was substantially justified. See
sec. 7430(c)(4)(B)(i); Rule 232(e); see also Corson v. Commissioner, 123 T.C. at
. 206. For purposes of determining …
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 RulingsApr 3, 2018
…e annual nontaxable portion of petitioner's annuity (i.e., $343.51 ×
12 = $4,122.12 rounds up to $4,123) such that CalPERS reported $27,850 as
taxable ($31,973 - $4,123 = $27,850).
3Petitioner does not dispute that the distributions from OneWest Bank are
taxable.
- 4 -
determinations erroneous. Rule 142(a); see INDOPCO…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
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 …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…ollowing calculation: 120,525 wholly physician-owned private practices × 1 hour × $113.77 = $13,712,123. Therefore, the total burden hours are 301,312 + 120,525 = 421,837 and the total equivalent costs are $36,925,829 + $13,712,123 = $50,637,952. The printing and material costs are $12,052. Therefore, $50,637,952 + $12…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCProposed Rules (FR)Proposed May 13, 2026
… their partner required fertility treatments to help them become pregnant or prevent a miscarriage.[123]
Rev. Rul. 2017-5 — This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effect… IRCRevenue RulingsFeb 27, 2017
…1970
2037
117,936
1971
2038
119,088
1972
2039
120,204
1973
2040
121,272
1974
2041
122,220
1975
2042
123,060
1976
2043
123,780
1977
2044
124,368
1978
2045
124,944
1979
2046
125,532
1980
2047
126,024
1981
2048
126,408
1982
2049
126,696
1983
2050
126,948
1984 and Later
2051 and Later
127,200
ATTACHMENT II
2017 ROUNDED COV…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…enerally. The Department assumes that 30 percent of plan assets are invested in a target date fund.[123]
IRCCourt RulingsJul 14, 2005
…nion supplements our prior
Opinion in Transp. Labor Contract/Leasing, Inc. & Subs. v.
Commissioner, 123 T.C. 154 (2004).
SERVED JUL 1 4 2005
- 2 -
motion for reconsideration of the Court's Opinion in this case
(petitioner's motion for reconsideration) set forth in 123 T.C.
154 (2004) (Transport Labor I) and petitioner'…
Notice 2010-83 — Funding relief for multiemployer defined benefit plans under PRA 2010. This notice provides guidance in the form of questions and answers for sponsors of multi… IRCNoticesDec 20, 2010
…hat future year. For example, The market value of assets as of January 1, 2010, is projected to be $123.45 [($113.50 * 1.07) + $12 - $10] and there is projected to be no difference between actual and expected returns for 2009.
Under the asset valuation method for the plan, the actuarial value of assets at January 1, 20…
IRCCourt RulingsSep 2, 2003
…ection
references are to the Internal Revenue Code for the relevant
year.
T.C. Summary Opinion 2003-123
UNITED STATES TAX COURT
GARY PAUL RUSH, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 04557-01S. Filed September 2, 2003.
Gary Paul Rush, pro se.
T. Richard Sealy III
and Catherine S. Tyson
,…