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82 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …rs. The equivalent cost is estimated as: 1 automatic portability provider × 10 hours × $159.34 = $1,593.40, rounded to $1,593. Back to Citation 157.  The hour burden is estimated as: 185,000 plans × 2/60 hours = 6,167 hours. The equivalent cost is estimated as: 185,000 plans × 2/60 hours × $63.45 = $391,275. Back to Ci…
  2. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    023). Back to Citation 696.  This is estimated as: 114,931,000 × 38.8% ≉ 44,593,228. Back to Citation 697.  In 2023, there were 67,781,000 IRAs. ( See Cerulli, The Cerulli Report, U.S. Retirement End-Investor 2023, Exhibit 5.12, (2023)). Back to Citation 698.  The number of plan participants receiving paper disclosures…
  3. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    ontrol of the use of the IRA distributions. We are not persuaded by respondent's argument that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the forfeiture, and his avoidance of a fine or potentially longer prison sentence, petitioner should be treated …
  4. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    owing differences: I --between the amounts of royalties and other expenses referred to in article 74 of the mentioned Law, credited or paid during the base-year, and the minimum percentages established for the respective deduction, according to (b) and (d); II--between the quotas for the purpose of forming depreciation…
  5. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  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. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997★ strong match
    …hy v. Commissioner , 87 T.C. 56, 64 (1986); Schuster's Express, Inc. v. Commissioner , 66 T.C. 588, 593 (1976), affd. per curiam 562 F.2d 39 (2d Cir. 1977); Rubin v. Commissioner , 56 T.C. 1155, 1163 (1971), affd. 460 F.2d 1216 (2d Cir. 1972). "Fair warning means that respondent's failure to give petitioner notice of […
  8. Court of Appeals for the Eleventh Circuit — Ann Johnson v. Russell Investments Trust Company
    ERISACourt RulingsAug 17, 2026
    …nsider and weigh competing evidence. See, e.g., Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 593 (1993) ; United States v. Robelo - Galo , 166 F.4th 1311, 1316 (11th Cir. 2026). To that end, in Pizarro ,
  9. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
  10. 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…
  11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  12. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
  13. 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…
  14. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …etitioners' gross income for the subject years includes interest income of $480, $231, $148, $798, $593, and $653, respectively. We hold that it does; 4. whether petitioners' gross income for the subject years includes "unreported income" of $11,122, $22,520, $8,502, $155,523, $110,720, and $88,965, respectively.5 We h…
  15. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    hat will have a selected a certified IDR entity, the annual burden would be 4,593 hours, with an annual equivalent cost estimate of $0.4 million.[258] The Departments assume that 5 percent of notices would be mailed and will incur a printing cost of $0.05 per page and $0.55 for postage. Thus, the mailing cost is estima…
  16. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  17. 89 T.C. 689; 89 T.C. No. 48 — William Bryen Co. v. Commissioner
    IRCCourt RulingsSep 29, 1987
    … his intention to proceed under that theory. Schuster’s Express, Inc. v. Commissioner, 66 T.C. 588, 593 (1976), affd. per curiam 562 F.2d 39 (2d Cir. 1977); Rubin v. Commissioner, 56 T.C. 1155, 1163 (1971), affd. 460 F.2d 1216 (2d Cir. 1972). Fair warning means that respondent’s failure to give petitioner notice of his…
  18. 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 …
  19. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    … 1985 final rule (50 FR 3892, 3895-96 (Jan. 29, 1985)). See also Bechtel v. PBGC, 624 F. Supp. 590, 593 (D.D.C. 1984), aff'd, Bechtel v. PBGC, 781 F.2d 906, 907 (D.C. Cir. 1986). Back to Citation 2.   Bechtel v. PBGC, 781 F.2d 906, 907 (D.C. Cir. 1986). Back to Citation 3.   Id. Back to Citation 4.  
  20. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    luded that the bulk of the $26 million received by hi s IRA was attributable to his relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…