91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…(A × B)
(A × B × C)
Notice Preparation (Service Providers)
3,552 Service Providers
1
$181.06
3,552
$643,125
Notice Preparation (In-House)
26,301 = 263,006 Small Plans × 10% Not Using a Service Provider
1
181.06
26,301
4,761,983
( printed page 9233)
Adding Contact and Plan Information to Drafted Notices
236,705 = 263,00…
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…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
,643 disclosures × 5 minutes) ÷ 60 minutes] = 15,387 hours. [(184,643 disclosures × 5 minutes) ÷ 60 minutes] × $63.45 = $976,301.
Back to Citation
48. The material and postage cost is estimated as: (184,643 disclosures × 4 pages × $0.05) + (184,643 disclosures × $0.66 postage) = $158,793.
Back to Citation
49.
Departm…
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…
IRCCourt RulingsJul 31, 2000
end of that year, the
conversion credit balance was $17,643.01 ($8,603.71 + $10,530 -
$2,250.45 + $759.75); the $759.75 is the interest of 4.5 percent earned on the conversion credit balance (($17,643.01 - $759.75) x
4.5% = $759.75)). Of the conversion credit balance, $8,380.43
could have been transferred at this time …
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsOct 10, 2018
… citation of United States v.
Craft, 535 U.S. 274, 283, 288 (2002), and Notice 2003-60, 2003-2 C.B. 643, 645.
S_e_e dissenting op. p. 89. As we have explained, see supra note 25, as of the time
of the CDP hearing Mr. Melasky cannot possibly have held the Exxon Mobil stock
as a tenant by the entirety. We also do not und…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…,225 in subsequent years. The three-year average cost burden associated with OPM requirements is $6,643. The Departments seek comment on the assumptions and calculations made in this ICR.
Table 33—HHS Summary Cost and Burden of IDR Entity Certification Starting in 2022
Estimated number of responses
Total annual
burden
…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
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 …
IRCCourt RulingsAug 10, 2015
…nd intention in engaging in the activity is to make a
profit. Dreicer v. Commissioner, 78 T.C. 642, 643 (1982), aff'd without published
opinion, 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of profit
need not be a reasonable one, but merely bona fide. Id ; sec. 1.183-2(a), Income
Tax Regs. Whether a taxpa…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…9
William Shaw V.P. Sales & 85,000 651,997 736,997
Marketing
Jim Discher Sr. Acct. Exec. 25,000 370,643 395,643
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…nvestors receiving paper disclosures is estimated as: (3,183,503 retirement investors × 5.8%) = 184,643 paper disclosures.
Back to Citation
479.
The cost is estimated as: (184,643 paper disclosures × 2 pages) × $0.05 = $18,464.
Back to Citation
480.
IRCRegulationsJul 26, 2016
…'s allocable portions of the investment in the contract after adjustment for the refund feature $76,643.18 Exclusion ratio for the contract as a whole (total adjusted investment in the contract, $76,643.18, divided by the total expected return from above, $134,580.00) (percent) 56.9
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…d returns showed income
as follows:
1999 2000 2001 2002 2003
Gross Income $630 ,054 $862,338 $1,990,643 $3,105,883 $2,836,896
Total Expenses 573,086 856,475 1,695,246 2,818,055 2,775,227
Net Income 56,968 5,863 295,397 287,828 61,669
For 2004, Special Agent Trogden examined the bank records of
four bank accounts titled…
IRCCourt RulingsFeb 9, 2023★ strong match
hich established decreasing
m aximum deductibility ceilings, ranging from five percent
to one percent of gross sales, in connection with (i) royalties paid for the license of patents; (ii) technology transfer
payments for unpatented technology (see paragraph 90 of
this Stipulation of F acts); and (iii) amounts paid for…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…