IRCCourt RulingsMar 24, 1993
…ant or division, to suggest that a partial termination has occurred. In re Gulf Pension Litigation, 764 F. Supp. at 1168; Morales v. Pan Am. Life Ins. Co., 718 F. Supp. at 1302-1303, and cases cited therein. A drop of less than 20 percent has been considered significant only if accompanied by egregious abuse on the par…
IRCCourt RulingsJan 14, 2013★ strong match
…s:6
Year Ms. Fletcher Dr. Fletcher
1973-1983 -0- -01984 $6,000 -01985 13,000 $12,923
1986 15,521 18,764
1987 26,769 29,077
1988 36,000 36,000
1989 36,000 36,000
1990 4,154 4,154
IRCCourt RulingsJul 31, 2000★ strong match
…nd,
at the end of that year, the conversion credit balance was $40,969.07 ($48,680 - $9,475.15 + $1,764.22); the $1,764.22 is
the interest of 4.5 percent earned on the conversion credit
balance (($40,969.07 - $1,764.22) x 4.5% = $1,764.22)). None of
the conversion credit balance could have been transferred at this
time…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…%
($100)
0.021%
($126)
From 0.000% to 0.001%.
(From $1 to $6).
Plans with 6-10 Participants
153,541
764,808
0.013%
($102)
0.013%
($100)
0.017%
($126)
From 0.001% to 0.002%.
(From $6 to $13).
Plans with 11-20 Participants
158,608
1,086,263
0.009%
($102)
0.009%
($100)
0.012%
($126)
From 0.001% to 0.002%.
(From $12 to $25…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCCourt RulingsJul 25, 2023
…ioner was employed by the N ew York City
Transit Authority. For that year it paid him wages o f $80,764, reporting
that amount to him on Form W – 2, Wage and T ax Statem ent . He does
not dispute that he received wages of $80,764 during 2018.
During 2018 petitioner received from the New York C ity Retirement Systems Tr…
IRCCourt RulingsSep 25, 1996
…and MPC under
the employee leasing agreement. The Termination Agreement stated
that MPC owed $2,148,764 to MIT 83 under the leasing agreement
(the $2,148,764 amount is an error; the amount that should have
appeared in the Termination Agreement was $2,135,260), and that
MPC offered to pay $1,899,633. MPC proposed to do …
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 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
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 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…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968★ strong match
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
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…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsAug 16, 2017related by meaning
en of proving that
those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290
U.S. I11, 115 (1933).
I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a
qualified retirement plan equal to 10% of the portion of the amount that is
includable in gros…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
… self-pay) individuals and providers and facilities is 255,524 hours with an equivalent cost of $29,764,646, as shown in Table 48.[304]
HHS invites comment on the assumptions and calculations made in this ICR.
Table 48—Annual Burden and Cost Related to Patient-Provider Dispute Resolution Process for Uninsured (Self-Pay…
IRCCourt RulingsSep 19, 2019related by meaning
e. Because petitioner raises only a legal issue, we
decide whether he is liable for the deficiency without regard to the burden of
proof.
II. Analysis Gross income generally includes distributions from an IRA under the
provisions of section 72. Sec. 408(d); see Sears v. Commissioner, T.C. Memo.
2010-146. Section 72(t)(…
79 FR 66617 — Revisions to Annual Return/Report-Multiple-Employer Plans ERISAFinal Rules (FR)Nov 10, 2014
…g, the Department estimates that 5,527 multiemployer plan administrators will spend approximately 2,764 hours complying with the CSEC Act requirements at an equivalent cost of approximately $173,000 (2,764 hours times $69 for the
( printed page 66621)
services of an in-house financial professional).[5]
The OMB emergenc…
146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner IRCCourt RulingsMar 29, 2016
…
Prorated 2003 property taxes $212.94
Earnest money deposit (cash) 60,000.00
Other cash payment 341,764.56
Promissory note to seller 200,000.00
Purchase price 601,977.50
IRCCourt RulingsMar 24, 1959
…ate Nonrene-gotiable Total Sales.. Net profit... Percentage.. $527,637 $150,991 28.61* i $16,490 $4,764 28.8 $544,127 $155,755 28.6 $432,637 $55, 991 12.9 $16,490 $4,764 28.8 $449,127 $60,755 13.5 1 Of this amount $16,054 represented sales of salted peanuts to the corporation and its subsidiary.
Petitioner’s invested c…