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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. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
   IRCCourt RulingsAug 17, 2026
   … Coastal Act. Redondo Beach Waterfront , LLC v. City of Redondo Beach, 265 Cal. Rptr. 3d 556 , 564, 569 (Ct. App. 2020). It would not be bound by LA County’s prior determination. Id. The Coastal Commission has final interpretive authority over the 2014 LCP. Charles A. Pratt Constr. Co. , 76 Cal. Rptr. 3d at 47 3 . Acco…
3. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
   IRCCourt RulingsMay 4, 1978
   …he submitted vouchers covering $9,869.90. During fiscal year 1973 he submitted vouchers covering $7,569.14 and charged back $2,050. During the calendar years 1971, 1972, and 1973 Huffaker received advances for travel and entertainment expenses and submitted vouchers for travel and entertainment expenses as follows: Yea…
4. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
   ERISAFinal Rules (FR)Apr 25, 2024
   … prepare the statement. This results in an hour burden of 9,474 hours with an equivalent cost of $1,569,868.[78] Table 3—Hour Burden and Equivalent Cost Associated With the Statement of the Care and Loyalty Obligation Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burden hours Equivalent burden co…
5. PLR 201935011 — Year of Deduction
   IRCPrivate Letter RulingsAug 30, 2019
   …nt plan under the objective outlay-of-assets test of Don E. Wi lliams Co. v. Commissioner, 429 U.S. 569 (1977) This memorandum provides general legal advice on the determination of whether a contribution by an employer to the employer’s qualified retirement plan has actually been pai d to the plan’s trust such that the…
6. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
   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’ …
7. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
   IRCCourt RulingsJul 30, 2007
   …nes 35 through 43, zeros on lines 53 through 59, zero total tax, Federal income tax withholding of $569, and a claimed refund of $569 . Under Rule - 5 - 91(f), it was deemed stipulated that petitioner failed to file a Federal income tax return for 2003 .
8. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJul 6, 2022related by meaning
   and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
9. 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…
10. 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…
11. PLR 201945024 — Year of Deduction
    IRCPrivate Letter RulingsNov 8, 2019
    … employer under section 414(b), (c), (m) or (o). In Don E. Williams Co. v. Commi ssioner , 429 U.S. 569 (1977), the Supreme Court held
12. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
13. Notice 2004-84 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Announcement 2004-71, 2004-40 I.R.B. 569, pertaining …
    IRCNoticesModified Dec 27, 2004
    …ist) described in section 10 of the draft revenue procedure in Announcement 2004-71, 2004-40 I.R.B. 569. The Internal Revenue Service intends to annually publish a Cumulative List to identify statutory, regulatory and guidance changes that must be taken into account in a plan sponsor’s submissions to the Service for op…
14. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …only in the case of an uncertainty. See Harry A. Wellons, Jr., M.D., S.C. v. Commissioner , 31 F.3d 569 (7th Cir. 1994), affg. T.C. Memo. 1992-704. Although the Prime Plan had features of deferred compensation (e.g., the payment of DWB's upon an employee's termination from employment based on his or her compensation an…
15. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68 (3d Cir…
16. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989related by meaning
    nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
17. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    f the distribution to $16,056 in calculating his adjustment to petitioner's tax liability. We will treat this reduction as a concession by respondent. 6As stated supra, petitioner's ERS plan was a qualified defined benefit plan under sec. 401(a). The sec. 72(t)(2)(E) exception applies only to distributions from an "ind…
18. Treas. Reg. § 1.411(d)-3(h) — Section 411(d)(6) protected benefits.
    IRCRegulationsJan 19, 2024
    … of $15,000) and the reduction in present value as a result of the amendment is $1,828 ($91,397—$89,569). In this case, the retirement-type subsidy at age 55 is the excess of the present value of the 50% early retirement benefit over the present value of the deferred payment of the accrued benefit, or $13,921 ($97,269—…
19. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
20. Treas. Reg. § 54.9802-4(f)(1)(ix) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover…
    IRCRegulationsAug 19, 2019
    …overage to its 10 part-time employees in rating area 1. Plan Sponsor H reasonably expects to employ 569 employees on the first day of the HRA plan year.