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76 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    … the total cost to prepare and send the annual termination form is approximately $197,857 annually.[663] The per-transaction cost is $20 annually, and the per-firm cost is $108 annually. Transaction Reporting The investment advice provider engaging in a covered transaction must give the authorizing fiduciary either a c…
  3. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …96,230, and Mr. Black's investment in the contract (in the form of aggregate premiums paid) was $86,663. Northwestern issued to Mr. Black a Form 1099-R, Distributions From Pensions, Annuities, Retirement Or Profit-Sharing Plans, IRAs, Insurance Contracts, Etc., for 2009 reflecting a gross distribution of $196,230 and a…
  4. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
  5. T.C. Memo. 1998-379 — Dale Reid Edmonds v. Commissioner
    IRCCourt RulingsOct 20, 1998
    …800 in taxable pension income, and a $7,140 loss from rental real estate, for a total income of $61,663. Petitioner claimed a $2,000 deduction for a contribution to an IRA and an $8,000 deduction for alimony paid, resulting in an adjusted gross income of $51,663. In the notice of deficiency, respondent determined that …
  6. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ordably to small investors even as they adapt business practices to mitigate conflicts of interest.[663] Because the core portfolio management functions are performed by computer algorithm, robo-adviser services generally can be expanded more easily than traditional advisory services. The marginal cost incurred by a ro…
  7. 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…
  8. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015★ strong match
    …nit determined petitioners' monthly gross income, monthly expenses, and monthly net income to be $8,663, $8,225, and $438, respectively. On the basis of petitioners' net realizable equity of $19,342.80 and monthly net
  9. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … Equity Acquisitions of Physician Medical Groups across Specialties, 2013-2016.” 323 JAMA 7 (2020): 663-665. Back to Citation 113.  Zhu, Jane M., Lynn M. Hua, and Daniel Polsky. “Private Equity Acquisitions of Physician Medical Groups across Specialties, 2013-2016.” 323 JAMA 7 (2020): 663-665. Back to Citation 114.  Ko…
  10. 74 T.C. 651 — Judd v. Commissioner
    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…
  11. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …rposeful, and intentional interference.2 ¹See Cox v. Mortg. Elec. Registration Sys., Inc., 685 F.3d 663, 671 (8th Cir. 2012) (holding that the plaintiff had not sufficiently pleaded the defendant's breach of its "duty of good faith and fair dealing by unjustified hindrance" of contract performance); In re Econ. Lodging…
  12. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
  13. PLR 200931049 — Ten or More Employer Plan Exception
    IRCPrivate Letter RulingsJul 31, 2009
    …. Such accounts must be sufficiently separate and independent to qualify as separate shares under § 663(c). The general test for separate and indepe ndent shares under § 663(c) is “whether distributions of the trust are to be made in substantially the same ma nner as if separate trusts had been created.” Treas. Reg. § …
  14. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    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…
  15. 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…
  16. 77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Nov 30, 2012
    …611 611 2,582 2,582 2016 623 623 2,633 2,633 2017 636 636 2,688 2,688 2018 649 649 2,745 2,745 2019 663 663 2,803 2,803 2020 677 677 2,861 2,861 2021 691 691 2,922 2,922 2022 706 706 2,983 2,983 2023 or later 720 720 3,046 3,046 1  Table II-A. 2  Table II-B. 3  Table II-C. ( printed page 71323) * * * * * Issued in Wash…
  17. 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 .
  18. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …1992 1993 1994 Total DWB's (number) 0 6 50 57 87 56 256 Withdrawal dist. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4,789,467 30,420,770 B. Suspense Account transact…
  19. 76 FR 74699 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 1, 2011
    …610 610 2,577 2,577 2017 623 623 2,632 2,632 2018 636 636 2,687 2,687 2019 649 649 2,743 2,743 2020 663 663 2,801 2,801 2021 677 677 2,860 2,860 2022 or later 691 691 2,920 2,920 1 Table II-A. 2 Table II-B. 3 Table II-C. * * * * * Issued in Washington, DC, this 18th day of November 2011. Laricke Blanchard, Deputy Direc…
  20. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …stion of fact to be resolved on the basis of the entire record. See Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). Because there is rarely a substantial market for sales of easements comparable to the donated easement , courts typically value conservation easements indirectly using a “before and after” approach . See…