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88 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    … a ruling that section 4973 impo ses a “ tax , ” not a “penalty” to which the provisions of section 6751 (b) c ould appl y . We a gree with respondent and w ill accordingly grant his Motion. Background The following facts are derived from the parties’ pleadings, M otion papers, and attached Exhibits. They are stated so…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …er requirements of 26 C.F.R. sec. 1.482-1(h)(2) (2006). See Ramm v. Commissioner , 72 T.C. 671, 674-675 (1979) ( finding it unnecessary for the Court to evaluate the validity of a requirement imposed by a regulation if the taxpayer did not satisfy the other requirements imposed by the regulation). G. C ircumvention or …
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    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…
  4. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    ders 1 $181.06 3,552 $643,125 Notice Preparation (In-House) 67,580 = 675,798 Small Plans × 10% Not Using a Service Provider 1 181.06 67,580 12,236,003 Adding Contact and Plan Information to Drafted Notices 608,218 = 675,798 Small Plans × 90% Using a Service Provider 5/60 70.29 50,685 3,562,639 Total 121,817 16,441,768 …
  5. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …$9,054. § 1903.15(d)(1) 124,709 126,749. § 1903.15(d)(2) 124,709 126,749. § 1903.15(d)(3) 12,471 12,675. § 1903.15(d)(4) 12,471 12,675. § 1903.15(d)(5) 12,471 12,675. § 1903.15(d)(6) 12,471 12,675. ( printed page 5383) Department of Labor Employee Benefits Security Administration Title 29—Labor PART 2575—ADJUSTMENT OF …
  6. Treas. Reg. § 1.401(l)-3(f)(3) — Permitted disparity for defined benefit plans.
    IRCRegulationsMay 18, 2016
    …ple 6 except that the plan reduces the gross benefit percentage for early retirement at age 55 to 1.675 percent. Because the gross benefit percentage is reduced by 0.325 percent (from 2.0 percent to 1.675 percent), the same percentage point reduction made in the offset percentage (from 0.65 percent to 0.325 percent), t…
  7. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …00 2/15/87 4,000.00 2/15/88 10,000.00 8/15/88 5,000.00 1/31/90 6,000.00 4/16/90 18,000.00 1/01/91 1,675.86 - 4 - Date Amount 5/22/91 2,151.47 3/24/92 2,500.00 6/17/92 5,000.00 Each loan is evidenced by a written note, and the terms of the notes are set forth on substantially identical forms. Each note requires repaymen…
  8. Treas. Reg. § 1.422-5(e) — Permissible provisions.
    IRCRegulationsSep 9, 2016
    …at $0 per share plus 15 shares at $25 per share)). In addition, A must recognize a capital gain of $675, which consists of $375 ($450, the amount realized from the sale of 15 shares, less A's basis of $75) plus $300 ($1,800, the amount realized from the sale of 60 shares, less A's basis of $1,500 resulting from the inc…
  9. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    moot, or irrelevant . To reflect the foregoing, Decision will be entere d for respondent . 8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the tax shown on the taxpayer's return for the year in question (or, if no return is filed, the taxpayer's tax…
  10. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017
    …n, for 2011 (2011 return). On the 2011 return petitioner reported taxable IRA distributions of $119,675,4 interest of $136 (including $5 of tax-exempt interest), a net business loss from a sole proprietorship of $39,379, and 2The Forms 1099-R that were included with petitioner's 2011 return as a stipulated exhibit do n…
  11. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … (hours) Total annual burden (hours) Total estimated labor cost Total estimated cost 2022 22,257 36,675 1.7981697 65,948 $6,464,751 $191,734 ( printed page 56086) 2023 22,257 36,675 1.7981697 65,948 6,464,751 185,452 2024 22,257 36,675 1.7981697 65,948 6,464,751 185,452 3 Year Average 22,257 36,675 1.7981697 65,948 6,4…
  12. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  13. 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…
  14. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  15. Treas. Reg. § 1.401-3(a)(3) — Requirements as to coverage.
    IRCRegulationsMar 14, 2019
    …igible to participate because of age requirements 150 (iii) Total employees eligible to participate 675 (iv) Percentage of employees in item (i) eligible to participate 81 + % (v) Minimum number of participating employees to qualify the plan (80 percent of 675) 540 If only 70 percent, or 578, of the 825 employees satis…
  16. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  17. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …health insurance with offer of fertility coverage in group plan × 16.6 percent offer rate) = 26,174,675 participants aged 25 to 45 enrolled in non-federal, employer-sponsored health insurance offered excepted fertility benefits coverage. Back to Citation 152.  National Center for Health Statistics, National Survey of F…
  18. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  19. 29 C.F.R. § 2530.200b-3(f)(4)(iii) — Determination of service to be credited to employees.
    ERISARegulationsJan 1, 2017
    …s of a vesting computation period an hourly employee is paid at a rate of $3.00 per hour and earns $675 for the performance of duties; during the next 6 months, the employee is paid at a rate of $3.50 per hour and earns $1,575 for the performance of duties; during the final 3 months the employee is paid at a rate of $3…
  20. 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 …