IRCCourt RulingsJun 9, 1965
…9 790,352.39
DEFERRED CHARGES
Factory supplies.— Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14
Total deferred charges. 13,049.01 13,049.01
FIXED ASSETS
IRCCourt RulingsMar 5, 2018★ strong match
…ble
Year income to FSC income FSC tax Dividends
1998 $686,808 $157,966 $48,077 $7,211 $150,754
1999 607,315 139,682 42,512 6,377 133,306
2000 600,414 138,095 42,029 6,304 131,791
2001 533,967 122,812 37,378 5,607 117,206
Total 533,057
D. The Limited Scope of the FSC Provisions
There were three parts to petitioners' tra…
IRCCourt RulingsJan 27, 2005
… the bankruptcy proceeding was reopened to
include in the bankruptcy estate a monetary judgment of $607,500
that petitioner recovered against a former employer, which, if
collected, would pay off all creditors. Therefore, petitioners
contend, pending collection of this asset, respondent, as a
creditor, is stayed from i…
IRCCourt RulingsMar 20, 1997related by meaning
series of substantially
equal periodic payments made for life; (5) to an employee after
separation from service after attainment of age 55; or (6) as dividends paid with respect to corporate stock described in
section 404(k).
- 14 -
6
Sec. 4975 imposes two levels of excise tax on "any
disqualified person who participa…
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…
IRCCourt RulingsSep 25, 2019related by meaning
d in section 401(a). See sec. 4974(c). Section 72(t)(2) provides
- 6 -
[*6] exceptions to imposition of the additional tax, including an exception for distributions made to taxpayers 59-1/2 years old or older. The term "deficiency"
is, in general, defined as the excess (if any) of the tax imposed over the amount
shown …
IRCCourt RulingsMar 31, 1997★ strong match
…
Petitioner claimed a deduction for contributions to the plans of
$101,787,413. Of that amount, $57,607,463 was reflected on
petitioner's books as a TYE 8801 expense, and $44,179,950 was
reflected on Schedule M-1 as an adjustment to petitioner's book
income.
Of the $44,179,950 deducted by petitioner on the Schedule M1,…
IRCRegulationsJul 26, 2016
…nt. When this is applied to the guaranteed amount of $20,250, it results in a refund adjustment of $607.50. The adjusted investment in the contract in $24,392.50 ($25,000—$607.50).
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCCourt RulingsJul 31, 2000
… premium of $2,846.44
($2,890.50 - $44.06). The cost of insuring Dr. Desai for the
second year was $607.89, and, at the end of that year, the
conversion credit balance was $4,865.74 ($2,373.60 + $2,890.50 -
$607.89 + $209.53); the $209.53 is the interest of 4.5 percent
earned on the conversion credit balance (($4,865.7…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
77 FR 74063 — Amendments to the Abandoned Plan Regulations ERISAProposed Rules (FR)Proposed Dec 12, 2012
…ar (3.1 million participants × .033 hours per participant × $28.21 per hour) in clerical time, and $607,000 (39,000 plans × .167 hours per plan × $93.31 per hour) in benefit manager costs. In addition, the Department assumes that each participant will receive a one page notice by first class mail resulting in a cost bu…
73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979related by meaning
In addition, section 1.401(b)-1(e), Income Tax Regs., authorizes the Commissioner to further extend the remedial amendment period at his discretion. 7 *42 *188 This provision, upon which petitioner relies, confers discretionary authority on the Commissioner. When reviewing discretionary administrative acts, this Court …
75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient… IRCFinal Rules (FR)Jul 23, 2010
…g costs for those prepared in-house listed in Table 2), is $243,000 in 2011, $443,000 in 2012, and $607,000 in 2013.
Type of Review:
New collection.
Agencies:
Employee Benefits Security Administration, Department of Labor; Internal Revenue Service, U.S. Department of the Treasury.
Title:
Affordable Care Act Internal Cl…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
… Island.
New York Regional Office, 201 Varick Street, Room 746, New York, NY 10014, telephone (212) 607-8600, fax (212) 607-8611; jurisdiction: southeastern New York, northern New Jersey.
Philadelphia Regional Office, 1835 Market Street, 21st Floor, Mailstop EBSA/21, Philadelphia, PA 19103, telephone (215) 861-5300, fa…