120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ded in 1991.
Mercer believed that Norwest’s resulting reserve for active and
retired employees ($30,689,717) would be with in the section
419A(c)(2) account limit.
On the basis of the 1991 valuation report, Norwest contributed
$30,689,717 to the postretirement medical trust in 1991. On the
consolidated return for 1991,…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…ting 33,820,000 tons sold over the l ife of the mine, ramping up from
383,402 tons in 2020 to 1,508,689 tons in 2028 and 1.44% annual growth
thereafter. He concluded total costs of production would be $6.25 per
ton with a 3% increase each year. Using a discount rate of 15%, he
calculated a net present value of approxim…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
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 RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
IRCCourt RulingsDec 29, 2005related by meaning
sion plan was formed
before June 25, 1959, because the corpus of that plan has existed
since 1949. Petitioner relies on Rapport de Gestion, UMR, which she states is available on a Web site. We have not considered
that document because it was not offered or admitted into
evidence.
Petitioner contends that we should take…
IRCCourt RulingsJul 8, 1980related by meaning
alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
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 RulingsJul 31, 2000
…, age 45. The first-year premium was $9,906, and the cost of
insuring Dr. Mall for that year was $1,689.85. The Neonatology
Plan paid the first-year premium, and, at the end of that year,
the conversion credit balance was $8,585.88 ($9,906 - $1,689.85 +
$369.73); the $369.73 is the interest of 4.5 percent earned on
the…
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 RulingsDec 8, 2010
…imberly-Clark distributed
petitioner's $40,063 of after-tax contributions directly to him.
The $398,689 balance of petitioner's section 401(k) account was
IRCCourt RulingsMay 27, 2004
…ows:
1996
1997
1998
1999
2000
$1,016 $1,016 $1,016 $1,016 $1,016
–- 2,236 2,236 2,236 2,236
-- -- 3,689 3,689 3,689
–- -- –- 4,058 4,058
–-
–-
--
–-
4,464
1,016 3,252 6,941 10,999 15,463
Respondent also determined on the basis of these regulations that
petitioner owed a second-tier excise tax of $124,079 for 2001.
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 RulingsJun 18, 1959
….66 298.43
Taxes. 1,074.34 2,140.98
Contributions. 206.00
Depreciation. 73.61 515.70
Depletion. 119,689.38 131,494.22
Other deductions. 5,385.15 11,026.00
Total deductions. (133,370.64) (161,352.83)
Net income.-120,210.13 131,494.22
Depletion computation:
Total production (sales) 1,714,327.10 1,935,793.57
Share of prof…
IRCCourt RulingsFeb 9, 2023
…vant factors.” Altera Corp. & Subs. v. Commissioner , 145 T.C. at 112 (quoting
Sherley v. Sebelius, 689 F.3d 776, 784 (D.C. Cir. 2012) ).
208
To the extent it matters whether the Treasury Department considered the
public comments, petitioner has conceded that the Treasury Department considered
the public comments. Firs…
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
ERISACourt RulingsAug 31, 2026
…166
F.4th 645, 649 (7th Cir. 2026); accord Meyer v. Duluth Bldg.
Trades Welfare Fund, 299 F.3d 686, 689 (8th Cir. 2002) ;
Penn v. Howe - Baker Engrs., Inc., 898 F.2d 1096, 1100 (5th
Cir. 1990).
III.
Liu argues that the Complaint plausibly alleg es
ERISACourt RulingsSep 17, 2026
… Bryan A. Garner, Reading Law 170–71 (2012)); see Servotronics, Inc. v. Rolls - Royce PLC, 975 F.3d 689, 694–95 (7th Cir.
2020) (“Identical words or phrases used in different parts of
the same statute … are presumed to have the same meaning.”).
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-263
UNITED STATES TAX COURT
RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v
.
COMMISSI…
IRCFinal Rules (FR)Aug 26, 2022
…laims will be $1,532,477. As shown in Table 5, HHS will account for a cost burden of approximately $689,615. DOL and the Department of the Treasury will each account for a cost burden of approximately $383,119. OPM will account for a cost burden of approximately $76,624.
Table 5—Summary Annual Cost and Burden Starting …