IRCCourt RulingsFeb 28, 2024★ strong match
…g each party’s Motion for Partial Summary
Judgment on the limitations issue.
6
For example, section 313 of the Act did not provide that the amendment applied to returns filed on or before the date of enactment if the period of limitations had
not expired as of such date, a formulation Congress used when amending sectio…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
HHS additionally proposes to redesignate 45 CFR 150.313(e)(1) and (2) as 45 CFR 150.313(h)(1) and (2) and also proposes to replace the title of the newly designated section to clarify that it pertains to a draft market conduct examination report. HHS also proposes to revise 45 CFR 150.313(e)(1), proposed to be redesign…
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 …
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsMay 20, 1976related by meaning
es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
IRCCourt RulingsAug 11, 1980
…ective July 1, 1968, the Delaware division of the Penn-Del-Jersey chapter of NECA — Local Union No. 313, IBEW Pension Plan (Local Pension) — had been established by collective bargaining between the Contractors’ Association and Local 313. Once the journeyman’s total compensation had been agreed upon in a collective bar…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…res will be mailed. Accordingly, the Department estimates an annual cost burden of approximately $2,313.[45]
Table 4—Material and Postage Cost Associated With the Disclosure
Year 1
Subsequent years
Pages
Equivalent
burden cost
Pages
Equivalent
burden cost
Material and Postage Cost
7
$2,313
7
$2,313
Total
7
2,313
7
2,…
IRCCourt RulingsMar 9, 2011related by meaning
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
IRCCourt RulingsDec 11, 2003related by meaning
oner
, supra
at 780.
11
See id.
at 773.
12
See Eckel v. Commissioner
, T.C. Memo. 1990-174.
13
See, e.g., In re Hatton
, 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang
, 164 F.3d 1029, 1033 (6th Cir. 1999).
section 6653(a),
3
section 6662,
4
section 6013,
5
section 6033,
6
section 6651(f),
7
section 6511,
8
sect…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979related by meaning
In addition, section 1.401(b)-1(e), Income Tax Regs., authorizes the Commissioner to further extend the remedial amendment period at his discretion. 7 *42 *188 This provision, upon which petitioner relies, confers discretionary authority on the Commissioner. When reviewing discretionary administrative acts, this Court …
IRCCourt RulingsAug 24, 2000
…between SLA and Filmways
was also executed on April 15, 1982, and provided for payment by
SLA of $1,313,000 to a separate account for payment of thirdparty invoices for advertising expenses. Filmways sent Richard
M. Greenberg a letter dated July 23, 1982, containing the
signature card and letter of authorization, both …
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 RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsSep 14, 2016
… taxable amount of IRA distributions was zero and that the taxable amount of pension income was $97,313, a total tax owed of $18,035, withholding
credits and other payments of $12,202, and a tax liability of $5,876. Perry had the
Form 1099-R from PSERS (which reflected a total taxable distribution of $58,255)
-6-
[*6] …
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCCourt RulingsMar 31, 1997related by meaning
t "on account of" the
earlier tax year in that the taxpayer had not proven that the
"same treatment requirement" of Rev. Rul. 76-28 was satisfied.
Id. (The only grace period contributions that we find to be "on
account of" TYE 8801 and which, consequently, must
be deducted in
that year, are any delinquent payments and …
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… suggesting an average prescription cost of $181 for combined insurer and participant expenditures.[313]
84 FR 55055 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Oct 15, 2019
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, rate set 313 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a valuation date
Immediate
annuity
rate
(percent)
Deferred annu…