IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsJan 20, 1983related by meaning
e, and we must therefore uphold its validity.
III. Petitioner’s Miscellaneous Contentions
1. Effective Date of Section 1.415-5(c)(l), Income Tax Regs. Section 1.415-1(f), Income Tax Regs., states that section 1.415-5(c)(l), Income Tax Regs., is effective for plan years beginning after 1975 and that, for all such plan y…
IRCCourt RulingsFeb 9, 2023related by meaning
ement of this title, including all rules and regul ations as may be
necessary by reason of any alteration of law in relation to internal
revenue.”
108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat.
at 917, was the provision in the Internal Revenue Code of 1954 that was
analogous to section 3791(b) of t…
IRCCourt RulingsNov 17, 2016related by meaning
culating the required reduction in the section 415 dollar limitation.
Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the
age 45 limits for tax years 2002 through 2006 are correct.
III. Petitioner's Liabilit…
89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Oct 28, 2024
…ear
Number of
respondents
Number of
responses
Burden hours per respondent
Total burden hours
Year 1
418
418
135
56,430
Year 2
418
418
60
25,080
Year 3
418
418
60
25,080
3-Year Average
418
418
85
35,530
Table 10—Estimated Department of the Treasury's Share of Total Burden Hours for Implementing the New Contraceptive Sta…
IRCCourt RulingsNov 2, 1998
…5. Characterization of New Mexico Losses
The fifth issue is whether petitioner is entitled to a $47,418
ordinary loss in 1993 stemming from an IRS forced tax sale of three
New Mexico properties he owned. Petitioner argues that he is
entitled to such a loss (arising from the difference between the
market value of the pr…
IRCProposed Rules (FR)Proposed May 13, 2026
…Total
811
152,127
893,408
Subsequent Year Total
406
76,064
893,408
Three-Year Average Total
541
101,418
893,408
Below is a summary of the burden associated with the collection of information.
Type of Review:
New.
Agency:
Employee Benefits Security Administration, U.S. Department of Labor; Internal Revenue Service, U.S.…
IRCCourt RulingsOct 9, 1997★ strong match
…the $1,937,701 disallowed in 1985 and deemed to have
been contributed on Jan. 1, 1986.
7
The $8,447,418 addition to the QAA comprises CIBU's of
$7,619,725, associated administrative costs of $395,683, and an
increase pursuant to sec. 419A(f)(7) of $432,010.
1986.
6
Second, the amount of the deduction shall not exceed t…
IRCCourt RulingsFeb 25, 2014
…ection 401(k) defined contribution plans. Sec.
401(a), (k); Felber v. Commissioner, T.C. Memo. 1992-418, aff'd without
published opinion, 998 F.2d 1018 (8th Cir. 1993). Because petitioner made
contributions to a plan described in section 401(a), she was an active participant
pursuant to section 219(g)(5), see sec. 1.21…
ERISAFinal Rules (FR)May 17, 2024
…ill spend, on average, 10 minutes per plan preparing and mailing the notices. This results in about 418 hours (2,506 plans × 10 minutes) of clerical staff time with an equivalent cost of $26,501 (418 hours × $63.45 per hour) and 418 hours of an accountant's time (2,506 plans × 10 minutes) with an equivalent cost of $48…
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
…23
Non-Depository Inst. and Credit Unions
2,853
0.23
0.25
223
82
FDIC
2,571
0.14
0.25
93
Board 224
418
0.18
0.25
19
OCC
1,399
0.16
0.25
55
NCUA
2,437
0.07
0.25
44
Total
9,810
416
Investigate and Verify Requirement for Additional Written Appraisal
Bureau
Depository Inst. > $10 B in total assets+
Depository Inst. Affili…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
ERISACourt RulingsSep 17, 2026
…licable
interest, 29 U.S.C. § 1399(c)(4), or a combination thereof. Milwaukee Brewery , 513 U.S. at 418. That said, how the MPPAA
calculates a company’s annual payment is not immediately
intuitive.
The Supreme Court perhaps put it best. The way the
MPPAA calculates the annual payment “is unusual in that the
statute doe…
IRCCourt RulingsMay 20, 1976related by meaning
he earned less than other dentists in the area but the best evidence of the value of his personal services is profit he derived from his own practice. As a final issue, we must decide whether the 5-percent addition to tax under section 6653(a) is applicable. In his statutory notice of deficiency, the Commissioner made …
78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal IRCProposed Rules (FR)Proposed Aug 8, 2013
…
123
Non-Depository Inst. and Credit Unions
2,853
0.23
0.25
159
82
FDIC
2,571
0.
0.25
93
Board 160
418
0.18
0.25
19
( printed page 48584)
OCC
1,399
0.16
0.25
55
NCUA
2,437
0.07
0.25
44
Total
9,810
416
Investigate and Verify Requirement for Additional Written Appraisal
Bureau:
Depository Inst. > $10 B in total assets +…
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 RulingsApr 11, 2012★ strong match
…mounts on their jointly filed Federal individual income tax returns:
2001 2002 2003
Gross income $1,418,560 $1,115,707 $1,142,511
Itemized deductions 122,512 110,429 27,462
Taxable income (loss) 1,296,048 1,005,278 1,115,049
Income tax 478,797 358,773 350,805
Brownsville Medical reported the following relevant amounts …
IRCCourt RulingsNov 23, 2016
… F.2d 68, 71 (7th Cir. 1986)).
22Nies v. Commissioner, T.C. Memo. 1985-216, 1985 Tax Ct. Memo LEXIS
418, at *14 (quoting Webster's Third New International Dictionary Unabridged).
23See Keating v. Commissioner, T.C. Memo. 1985-312, 1985 Tax Ct. Memo
LEXIS 329, at *13-*14; Nies v. Commissioner, 1985 Tax Ct. Memo LEXIS 41…
IRCCourt RulingsJun 10, 1996
…een applied where a partnership
converted to a corporation. See United States v. Kintner
, 216
F.2d 418 (9th Cir. 1954) (former partners given credit for past
16
service with the partnership for purposes of the 3-year
eligibility requirement for participation in the association's
plan); Farley Funeral Home, Inc. v. Com…
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…