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75 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    …lements 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's motion …
  3. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    IRCCourt RulingsMar 3, 2016
    … to the IRS, the income was not included on the income tax return: a Form 1099-R reporting the $109,154 IRA distribution from RBS Citizens Bank; a Form 1099-INT, Interest Income, reporting interest income of $13 from EMC Mortgage Corp.; a Form 1099-DIV, Dividends and Distributions, reporting taxable dividend income of …
  4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …5 13,000 $12,923 1986 15,521 18,764 1987 26,769 29,077 1988 36,000 36,000 1989 36,000 36,000 1990 4,154 4,154
  5. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  6. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …atements Pre-Statute 96.1 3.9 0.0 $0 $0 $0 $0 $0 1 51.3 48.7 44.8 53,502,795 18,284,236 4,949,140 5,154,737 81,890,909 2 57.3 42.7 38.8 0 0 0 4,471,532 4,471,532 3 60.2 39.8 35.9 0 0 0 4,139,119 4,139,119 4 61.7 38.3 34.4 0 0 0 3,977,383 3,977,383 5 62.3 37.7 33.8 0 0 0 3,898,691 3,898,691 6 62.7 37.3 33.4 0 0 0 3,860,…
  7. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    bility for income tax for 2004 that exceeded $1,000, net of any section 31 credit, and has taken judicial notice of the fact that petitioner had a tax liability in 2003. Therefore, the Court sustains respondent's determination of the addition to tax pursuant to section 6654(a). The Court has considered all of petitione…
  8. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … additional performance metrics for private funds—such as: (1) the public market equivalent (PME); [154] (2) the modified IRR (MIRR) which adjusts for timing of investment flows; (3) the multiple on invested capital (MOIC) which measures the total value returned to investor relative to the total capital invested; [155]…
  9. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  10. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ir health-care budgets, with the median share rising from 21 percent in 2021 to 27 percent in 2023.[154]
  11. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    … PROCEDURE? 152 .01 In general 152 .02 Specific changes 153 PART I. GENERALLY APPLICABLE PROCEDURES 154 >SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 154 .01 In general 154 .02 Letter ruling 154 .03 Closing agreement 154 .04 Determination letter 154 .05 Opinion letter 155 .06 Ora…
  12. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    Rev. Proc. 2020–4 TABLE OF CONTENTS SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 154 .01 Purpose of revenue procedure 154 .02 Organization of revenue procedure 154 .03 Other guidance affecting this revenue procedure 154 .04 Updated annually 157 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 20…
  13. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …l years previously. Between 2003 and 2006 petitioners made additional after-tax investments of $346,154 in the Allstate annuity contract. In March 2007 petitioners surrendered the Allstate annuity and transferred the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of the Al…
  14. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    … revenue procedure 152 .03 Other guidance affecting this revenue procedure 152 .04 Updated annually 154 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4? 154 .01 In general 154 .02 Changes made to Revenue Procedure 2018–4 154 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PR…
  15. T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner
    IRCCourt RulingsApr 27, 1998★ strong match
    T.C. Memo. 1998-154 UNITED STATES TAX COURT ESTATE OF MARTIN J. MACHAT, DECEASED, AVRIL GIACOBBI AND ERIC R. SKLAR, EXECUTORS, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21573-96. Filed April 27, 1998. Richard S. Kestenbaum and Bernard S. Mark , for petitioner. Janet F. Appel and Donald A. G…
  16. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  17. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …ner's contributions in the amount of - 6 - $18,112.25, and the taxable amount as the difference or $154,446.89. On their Federal income tax return for 1989, petitioners disclosed the receipt of the Transfer Refund. Specifically, on line 17a of Form 1040, petitioners entered $154,447 as the amount of "Total pensions and…
  18. 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…
  19. T.C. Memo. 2016-172 — Bonita L. Perry v. Commissioner
    IRCCourt RulingsSep 14, 2016
    … tax deficiency of $15,949 stemmed from the IRS's determination that Perry had received a total of $154,255 of taxable retirement income in 2011 but had reported only $97,313. The $154,255 amount was composed of $96,000 from Freedom Credit Union and $58,255 from PSERS. The difference between the proposed amount of taxa…
  20. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    Cumulative Difference -0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji 1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3 Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…