IRCCourt RulingsFeb 25, 2014
…ge); see also Hildebrand v.
Commissioner, 683 F.2d 57, 58-59 (3d Cir. 1982), a_ff'g T.C. Memo. 1980-532;
Eanes v. Commissioner, 85 T.C. 168, 170 (1985).7
For a taxpayer who is an active participant and whose filing status is single,
section 219(g) provides that the dollar amount of the allowable deduction under
section…
IRCCourt RulingsApr 12, 2011
8,532 by loans, and $3,674 by dividends. The following
table shows how he paid the premium each year:
Year Paid by Check Paid by Loan Paid by Dividend 1982 $1,837 -0- -01983 1,837 -0- -01984 1,837 -0- -01985 1,837 -0- -01986 1,837 -0- -01987 -0- $1,837 -01988 -0- 1,837 -01989 -0- 1,837 -01990 -0- 1,837 -01991 -0- 1,837…
IRCCourt RulingsJan 26, 2006
…come. While it appears that the $8,613 represents the sum of the $7,089.95 loan distribution
and $1,532 of the $15,322.69 distribution, the total of those two
amounts is $8,621.95. The record does not explain this
apparently erroneous computation. However, petitioner does not
dispute receipt of either distribution.
Pet…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…00 × 0.000333 × 0.69 × 0.1= 4,899).
Back to Citation
252.
This is calculated as 4,899/(1−0.25) = 6,532.
Back to Citation
253.
The burden is estimated as follows: 6,532 claims × 2 hours + 6,532 claims × 0.25 hours = 14,696 hours. A labor rate of $105.01 is used for a medical and health services manager and a labor rat…
ERISACourt RulingsAug 14, 2026
… 2023). It is “an equitable doctrine
invoked by a court at its discretion.” New Hampshire v. Maine, 532 U.S. 742, 750 (2001) (quoting Russell v. Rolfs, 893 F.2d 1033,
1037 (9th Cir. 1990)).
Judicial estoppel is “‘not reducible to any general formulation of principle,’ though the inquiry is typically informed
by several…
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 RulingsApr 16, 2020
…pplies 390 390 --- 390
Rent/lease 533 533 --- 533
Legal and professional 850 850 --- 850
Interest 4,532 4,532 --- 4,532
Depreciation 33,875 33,875 --- 33,875
Car and truck 5,506 5,506 --- 5,506
i. Other Expenses
We have found that in 2013 petitioner husband, on behalf of GSE, paid
$4,465 for taxes and licensing fees, p…
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 RulingsNov 6, 2012related by meaning
oneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However,
the Commissioner bears the burden of proof with respect to any increase in deficiency. See Rule 142(a)(1). Our conclusion, however, is based on a
preponderance of the evidence, and thus the allocation of the burden of proof is
immaterial. See E…
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 RulingsMar 11, 2020related by meaning
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…
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…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…
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
3,841,774
3…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsMar 12, 2008★ strong match
…166,388 14,311 180,699
-11 -
18 180,699 25,000 155,699 13,456 169,15 5
19 169,155 25,000 144,155 12,532 156,68 8
20 156,688 25,000 131,688 11,535 143,22 3
21 143,223 25,000 118,223 10,458 128,68 0
22 128,680 25,000 103,680 9,294 112,97 5
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsDec 2, 2010related by meaning
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…
IRCRegulationsJan 19, 2024
…($1,500 × 75%), and the corresponding single-sum amount payable to T is $1,125 × 14.632 × 12 = $197,532. (Note that this amount is larger than the age-60 present value of T's accrued benefit without taking mortality before age 65 into account, $1,500 × 10.209 × 12 = $183,762.) Participant T elects to receive a partial …
IRCCourt RulingsJul 30, 2012
…contribution to capital is not considered a
debt. United States v. Uneco, Inc. (In re Uneco, Inc.), 532 F.2d 1204, 1207 (8th
Cir. 1976); sec. 1.166-1(c), Income Tax Regs. To determine whether a bona fide
debt exists, we consider objective and subjective factors. In re Uneco, Inc., 532
F.2d at 1209.
Petitioner's transfe…