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76 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    ilian restrictions on payments by 3M Brazil are disregarded. We reject petitioner’s various arguments that the regulation is invalid. FINDINGS OF FACT Petitioner and respondent executed a stipulation of facts, which they later replaced with an amended stipulation of facts. The amended stipulation of facts is referred t…
  2. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010★ strong match
    . 806, 814 (1980). In Dew v. Commissioner, 91 T.C. 615, 626 (1988), the Court imposed a I section 6673 penalty against taxpayer, when he "persisted in "(...continued) years. All you ever do is steal my filing..fee." - 13 - pursuing" the case even after being told his position was frivolous or groundless. In Dew v. Comm…
  3. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    … costs   (A) (B) (C) = (A × B) (D) (E) = (C × D) First Year * 68,134,832 100.0 68,134,832 $0.20 $13,626,966 Second Year 32,650,854 100.0 32,650,854 0.20 6,530,171 Third Year 32,650,854 100.0 32,650,854 0.20 6,530,171 Three-Year Average 44,478,847 44,478,847 $8,895,769 Note:
  4. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    IRCCourt RulingsApr 26, 2005related by meaning
    t, as follows: (a) General: Disposition of an action for declaratory judgment which involves the initial qualification of a retirement plan * * * will ordinarily be made on the basis of the administrative record, as defined in Rule 210(b)(12). Only with the permission of the Court, upon good cause shown, will any party…
  5. Treas. Reg. § 1.72-5(b)(7) — Expected return.
    IRCRegulationsJul 26, 2016
    to such years, but in the sixth year he receives a total of only $626.40 rather than the $955.20 allocable to such year. A is 69 and B is 61 at the beginning of the first monthly period for which an amount is payable in the seventh taxable year. A makes the election in that year provided under paragraph (d)(3) of § 1.7…
  6. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …ederal estate tax attributable to that item of IRD. Estate of Smith v. United States, 391 F.3d 621, 626 (5th Cir. 2004) (citing sec. 691(c)), affg. 300 F. Supp. 2d 474 (S.D. Tex. 2004). Therefore, decedent's beneficiaries will be allowed a deduction in the amount of Federal estate tax paid on the items of IRD included …
  7. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …7), and aff'g Casebeer v. Commissioner, T.C. Memo. 1987-628, Moore v. Commissioner, T.C. Memo. 1987-626, and Sturm v. Commissioner, T.C. Memo. 1987-625. See Sacks v. Commissioner, 69 F.3d at 988 ("Our analytic task is to decide whether Mr. Sacks'
  8. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996★ strong match
    part, revg. in part, and remanding T.C. Memo. 1986-569. A detailed examination of these factors would result in a decision against petitioners. Factor (1) (manner in which taxpayer carries on the activity) in particular weighs heavily against petitioners. you to testify to the true facts that you knew that you were at …
  9. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015★ strong match
    ayer liable for tax if the taxpayer fails to pay the tax within 10 days after notice and demand for payment. Section 6330(a) provides that no levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of the right to a hearing before the levy is made. Se…
  10. 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’ …
  11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000★ strong match
    …the plan. On their joint 1992 and 1993 Federal individual income tax returns, the Malls reported $1,626 and $3,654, respectively, as P.S. 58 income. 17 - 30 - 17 (...continued) her life). During the subject years, Commonwealth paid the following commissions on the C-group products issued on the Malls’ lives: Period Beg…
  12. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
  13. Ann. 2013-21 — This announcement provides a revised Acknowledgment Letter, attached to Rev. Proc. 2013-12, 2013-4 I.R.B. 313. The telephone number that taxpayers use to inqui…
    IRCAnnouncementsApr 22, 2013
    …“VCP”) submission that has been sent to the IRS has changed as of March 27, 2013. The new number is 626-927-2011. Accordingly, this requires a revision to the Acknowledgement Letter, attached to Rev. Proc. 2013-12, 2013-4 I.R.B. 313. The Acknowledgement Letter is revised to include the updated telephone number. The pre…
  14. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  15. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …p-content/​uploads/​2018/​06/​WTW71824_​WHITE-PAPER_​Georgetown-CRI-Target-Date_​Jun-18_​Final.vs2_​626.pdf. Back to Citation 177.  Angela Antonelli, The Evolution of Target Date Funds: Using Alternatives to Improve Retirement Plan Outcomes, Geo. Univ. McCourt Sch. of Pub. Pol'y Ctr. for Ret. Initiatives (June 2018), h…
  16. 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…
  17. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …ta, Wyoming. Los Angeles Regional Office, 35 N Lake Ave., Suite 300, Pasadena, CA 91101, telephone (626) 229-1000, fax (626) 229-1098; jurisdiction: 10 southern counties of California, Arizona, Hawaii, American Samoa, Guam, Wake Island. New York Regional Office, 201 Varick Street, Room 746, New York, NY 10014, telephon…
  18. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976related by meaning
    loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
  19. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    … savings of S23,617.10. Subsequent years average: 605,806 fewer notices required × 3.9% mailed = 23,626 fewer notices. Each notice is estimated as 5 pages and mailed first class at a cost of $0.66 per notice. The cost is (5 pages × $0.05 per page) = $0.25 per notice + $0.66 for postage, resulting in a cost of $0.91 per…
  20. 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…