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79 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    …ted by the legislators. Barr v. United States, 324 U.S. 83 (1945); Zuanich v. Commissioner, 77 T.C. 428 (1981); Rechner v. Commissioner, 30 T.C. 186 (1958). Unless indicated otherwise, all Rule references are to the Tax Court Rules of Practice & Procedure. SEC. 61. GROSS INCOME DEFINED. (a) General Definition. — Except…
  2. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …her petitioners' gross income for the subject years includes rental income of $21,113, $11,460, $13,428, $33,994, $57,166, and $22,272, respectively. We hold that it does. We also decide whether petitioners may deduct
  3. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …r affected homeworker Minor Substantial Repeated, intentional or knowing Recordkeeping $21-214 $214-428 $428-1,071 Monetary violations 21-214 214-428 Employment of homeworkers without a certificate 214-428 428-1,071 Other violations of statutes, regulations or employer assurances 21-214 214-428 428-1,071
  4. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …ule C, Profit and Loss From Business, of his 1995 tax return, petitioner reported deductions of $70,428.52 from his automobile drag racing activity named Emerson Racing Enterprises. Petitioner reported no income from this activity, resulting in a $70,428.52 loss. Related to this loss in 1995, petitioner carried back a …
  5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005
    … the Court did not consider the precedential effect of Beech Trucking Co. v. Commissioner, 118 T.C. 428 (2002) (Beech Trucking Co.), and (b) the factors used in
  6. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  7. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    …ng the magistrate judge's findihgs and recommendation. On December 7, 2009, FHB issued a check for $428,103.63 from petitioner's IRA to the clerk of the District Court. Additionally, on December 8, 2009, FHB i sued a check for $89,343.98 from petitioner's IRA to UPW. Thereafter, FHB issued a Form 1099-R, Distributions …
  8. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    … § 726.302(c)(2)(i) table $139 $143. § 726.302(c)(2)(i) table 278 285. § 726.302(c)(2)(i) table 417 428. § 726.302(c)(2)(i) table 555 569. § 726.302(c)(4) January 2, 2018 January 23, 2019. § 726.302(c)(4) $139 $143. § 726.302(c)(5) January 2, 2018 January 23, 2019. § 726.302(c)(5) $417 $428. § 726.302(c)(6) January 2, …
  9. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …Apart 33,000 33,000 550.00 16,280 Sub-Total 17,384,942 8,708,971 145,150 4,296,426 Uniform Glossary 428,232 428,232 7,137 211,261 Notice of Modification 342,585 171,293 2,855 84,504 Individual Market: SBC with Coverage Examples 21,784,217 6,535,265 108,921 3,224,064 Uniform Glossary 762,448 762,448 12,707 376,141 Notic…
  10. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  11. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ll insurance companies is estimated as: [259,230 × (358 entities × 73.1% SBA small entities)] ≉ 189,428 retrospective reviews. Back to Citation 854.  This burden is estimated as: (189,428 reviews by small entities × 1 hour) ≉ 189,428 hours. A labor rate of $165.71 is used for a legal professional. The labor rate is app…
  12. 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…
  13. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    e 4 - 10 - of Exhibits 12-P and 16-P. We disagree. Page 4 of those Exhibits does not so state. To qualify under section 501(c)(18), the plan must have been funded solely by employee contributions. There is no evidence of the source of funding of the French pension plan other than petitioner's $1,916 payment in 2001. To…
  14. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  15. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  16. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  17. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …oan. Ex. C32. On August 26, 1987, Respondents rolled over the proceeds of CD No. 350, totaling $173,428.64, into CD No. 11813-17493 issued by TC.9 Ex. C23; Respondent's Response to Complainant's Interrogatory No. 34 at 10. Thereafter, on October 13, 1987, CD No. 346 matured, and Respondents rolled over its proceeds, in…
  18. 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 …
  19. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960
    …owed the deduction. On January 1, 1951, petitioner bad a reserve for bad debts in the amount of $2G,428.41. During the years 1949 to 1958, inclusive, petitioner had the following bad debts which were charged against the reserve in each of the years as follows: Bad debts charged' Year against reserve 1949 _$2,160.91 195…
  20. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989
    …Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. 2d Sess. at 169 (1962), 1962-3 C.B. 707, 731. Cf. Sanford v. Commissioner, 50 T.C. 823, 826 (1968), affd. per curiam 412 F. 2d 201 …