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78 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    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…
  2. 78 FR 26727 — Pension Benefit Statements
    ERISAProposed Rules (FR)Proposed May 8, 2013
    ry's benefit statement might look something like this: Current Balance Projected Balance $125,000 $557,534 Monthly Payment Monthly Payment $625 $2,788 This shows both total balances (current and projected) and the monthly payments generated by each. The projected balance ($557,534) and related monthly payment ($2,788) …
  3. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    eir RCP has changed since the time of the settlement officer's determination because of their middle son's death. 1. Collection Alternatives Generally During the course of a section 6330 hearing taxpayers may propose collection alternatives such as an OIC or an installment agreement. Sec. 6330(c)(2)(A)(iii); Giamelli v…
  4. 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…
  5. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …efore taxes FY ended taxes of GSI & subsidiaries GSI & subsidiaries June 30, 1988 $4,302,286 $5,748,557 June 30, 1989 9,725,667 9,759,287 June 30, 1990 11,111,080 11,111,080 June 30, 1991 3,224,665 2,237,628 BI's transition from providing services only to local merchants, service stations, and banks, to serving some la…
  6. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    6.46 6.68 H. Normal cost (beginning of year) 3 7,557,754 8,682,914 9,523,819 11,286,962 I. Benefits paid during year N/A 4,078,160 4,859,441 5,301,930 J. Employee contributions during year N/A 473,833 736,176 784,906 K. Interest to yearend 4 498,812 896,239 1,225,134 1,454,591 L. Account limit (yearend) 5 8,056,566 14,…
  7. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    …of the enacted relief until six years into the future. Cf. Lyons v. United States, 99 Fed. Cl. 552, 557 (2011) (“ The Court believes it would be a great surprise to the Congresses of 1938 and 2004 to discover that the law they passed . . . might not assist any person who was wrongfully imprisoned at that time, but poss…
  8. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    on payments of $30,557 for 2010, and respondent has conceded that this amount is not subject to the additional tax. The record contains no evidence of additional qualified education expenses paid for 2010 or any qualified education expenses paid for 2011.¹5 Accordingly, we find petitioners liable for the 10% additional…
  9. U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner
    IRCCourt RulingsJun 26, 2018
    …1 (defined as the plan year and limitation year in the ESOP's plan document). Mr. Essy received $41,557 and $40,000 in wages in the 2000 and 2001 calendar years, respectively. There is no information regarding the amount Mr. Essy specifically earned during the 12month limitation year from April 1, 2000, to March 31, 20…
  10. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …ne 19.b, and the interest due was shown on line 19.c. For 2003, line 19.a showed the tax due as $10,557; line 19.b (for penalties) was blank; and line 19.c showed the interest due "computed to 05/29/2011" as zero (specifically "0.00"). The sum of all three amounts due was shown as $10,557. For 2004, line 19.a showed th…
  11. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  12. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    y [section 403(a) of ERTA], then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent. [1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
  13. 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 …
  14. 73 T.C. 700 — Grant-Jacoby, Inc. v. Commissioner
    IRCCourt RulingsJan 16, 1980
    …e deductibility of the contributions is governed by section 404(a)(5). In Educo, Inc. v. Alexander, 557 F.2d 617, 622 (1977), the Seventh Circuit, in reference to plans administered by Educo, stated that such plans “are clearly characterizable as deferred-compensation plans.” The issue before the Court of Appeals in th…
  15. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …ing relevant amounts on its income tax returns: 2001 2002 2003 Total incomel $719,437 $741,101 $881,557 Less: Total deductions 702,992 ' 741,037 882,456 Net operating loss 19 825 3,380 3,316 carryover >380 (3 316) (4,215) Taxable income ; ( 3> ) '
  16. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  17. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011★ strong match
    …ted for those years DISC commissions of $465,392, $334,315, and $297,052 and taxable income of $463,557, $333,119,.and $294,657, 'respectively. ADF deducted the payment of these DISC commissions to ADF International·. (2) As a result of its status as a-DISC, ADF International was deemed to have made distributions of . …
  18. T.C. Memo. 2006-101 — Eugenie Denise Mitchell v. Commissioner
    IRCCourt RulingsMay 11, 2006related by meaning
    T. C. Memo. 2006-101 CA l STA UNITED STATES TAX COURT . . EUGENIE DENISE MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7144-04. Filed May ll, 2006. Eugenie Denise Mitchell, pro se. Margaret A. Martin· and Daniel J. Parent, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, …
  19. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …o the p lan administrator directly (quoting § 1024(b)(4)) ); Mondry v. Am . Fam . Mut. Ins . Co . , 557 F.3d 781, 796 (7th Cir. 2009) (holding that § 1024(b)(4) require d the production of a claims administration agreement because , in defin ing the respective roles of the plan and claims administrators , the agreement…
  20. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …o the p lan administrator directly (quoting § 1024(b)(4)) ); Mondry v. Am . Fam . Mut. Ins . Co . , 557 F.3d 781, 796 (7th Cir. 2009) (holding that § 1024(b)(4) require d the production of a claims administration agreement because , in defin ing the respective roles of the plan and claims administrators , the agreement…