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…
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 …
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…
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
…
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 …
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…
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…
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…
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…
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…
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…
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…
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 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…
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…
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…
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…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
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…
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 …