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…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
tions specialist. The labor rate is applied in the following calculation: 1,749,471 claims × 0.50 hours × $101.32 = $88,628,201.
Back to Citation
285. The burden is estimated as follows: 1,749,471 uninsured individuals in need of good faith estimates with additional items and services × 0.50 hours = 874,736 hours. A l…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…alty for a serious violation under section 17(b) of the Act, 29 U.S.C. 666(b), shall not exceed $12,471.
(4)
Other-than-serious violation.
The penalty for an other-than-serious violation under section 17(c) of the Act, 29 U.S.C. 666(c), shall not exceed $12,471.
(5)
Failure to correct violation.
The penalty for a failu…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
…$8,908
$9,054.
§ 1903.15(d)(1)
124,709
126,749.
§ 1903.15(d)(2)
124,709
126,749.
§ 1903.15(d)(3)
12,471
12,675.
§ 1903.15(d)(4)
12,471
12,675.
§ 1903.15(d)(5)
12,471
12,675.
§ 1903.15(d)(6)
12,471
12,675.
( printed page 5383)
Department of Labor
Employee Benefits Security Administration
Title 29—Labor
PART 2575—ADJUSTM…
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…
IRCCourt RulingsDec 2, 2010★ strong match
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…s Bowl Mobile Estates, 288 P.3d at 72 1 (quoting Charles
A. Pratt Constr. Co. , 76 Cal. Rptr. 3d at 471) . Therefore, the VTTM did
not “lock in” application of the 1981 Malibu LUP LCP. See Cal. Gov’t
Code § 66498.6(b). California caselaw confirms that the Coastal
Commission may apply a later-certified local coastal pro…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
…IANCE
.01 Effect of EPCRS on retirement plans . . .. . .. . .. . .. . ............................. 471 .02 Compliance statement ..................................................................... 471
.03 Excise and other taxes . . .................................................................. 471
.04 Reliance ..…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsMar 31, 2005
… 1099, that substantiates her claim that she made
payments of mortgage interest in the amount of $2,471.09 in
taxable year 1999. Petitioner’s only evidence, in this respect,
is a statement from First Community Financial Services addressed
to Mr. Seidel reflecting that he paid $2,471.09 in interest in
taxable year 1999.…
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…
IRCCourt RulingsJan 6, 1997
…cords to keep track of an individual's
contribution does not satisfy this requirement.
[ Id.
at
470-471; emphasis added.]
The Ninth Circuit went on to observe that, because Malbon's
benefits were determined on the basis of average salary and years
of service and because the return of his contributions included
no incre…
IRCCourt RulingsJan 9, 1985related by meaning
erest) on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner IRCCourt RulingsFeb 7, 2007
…...continued)
Appeals for the Sixth, Ninth, and Tenth Circuits. See, e.g.,
Hansen v. Commissioner
, 471 F.3d 1021 (9th Cir. 2006), affg. T.C.
Memo. 2004-269; Mortensen v. Commissioner
, 440 F.3d 375, 390-391
(6th Cir. 2006), affg. T.C. Memo. 2004-279; Van Scoten v.
Commissioner
, 439 F.3d 1243, 1254-1256 (10th Cir. 200…
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…
IRCCourt RulingsMay 19, 2011
…,953
6997-08 Mark E. Warmoth 2002 14,836 2,967
2003 1,252,944 250,589
15166-08 Mark E. Warmoth 2004 471,615 94,323
All monetary amounts have been rounded to the nearest
dollar. Respondent subsequently asserted an increased deficiency
in each docket. See infra pp. 33-36.
Petitioners contested the determinations by filin…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…0
$0
1
51.3
48.7
44.8
53,502,795 18,284,236
4,949,140
5,154,737
81,890,909
2
57.3
42.7
38.8
0
0
0
4,471,532
4,471,532
3
60.2
39.8
35.9
0
0
0
4,139,119
4,139,119
4
61.7
38.3
34.4
0
0
0
3,977,383
3,977,383
5
62.3
37.7
33.8
0
0
0
3,898,691
3,898,691
6
62.7
37.3
33.4
0
0
0
3,860,403
3,860,403
7
62.8
37.2
33.3
0
0
0
3,841,7…
IRCCourt RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …
IRCCourt RulingsMar 11, 2020★ strong match
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…