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82 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …h amount is less than 5 percent of petitioner’s actual sales of television bulbs for 1949 of $8,174,895.13. Therefore, it is the contention of Kimble Glass that it satisfies the test set forth in clause (iii) of section 435(e)(1)(B).
  2. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998★ strong match
    …e Co. (Great-West). GreatWest mailed to petitioner and to respondent a Form 1099-R indicating that $895 of the $5,149 distribution represented taxable income to petitioner. 1994 Tax Return and Respondent's Audit On her 1994 Federal income tax return, petitioner did not report any taxable income relating to the transfer…
  3. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …ion of Notices (Hour Burden) 43,172 0 14,391 Printing Costs (Cost Burden) $13,626,966 $6,530,171 $8,895,769 ( printed page 46624) Agency: Employee Benefits Security Administration. Title: Electronic Disclosure by Group Health Plans Under ERISA. Type of Review: New. OMB Control Number: 1210-NEW. Affected Public: Individ…
  4. 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…
  5. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …097 54,223 19,669 34,554 1999 51,296 26,112 25,184 52,014 3,112 48,902 1998 49,489 26,500 22,989 49,895 -0- 49,895 1997 47,746 26,500 21,246 47,862 -0- 47,862 1996 46,064 26,500 19,564 45,912 -0- 45,912 1995 44,441 25,885 18,556 44,042 -0- 44,042 1994 42,876 23,331 19,545 10,562 -0- 10,562 1993 41,365 20,800 20,565 10,…
  7. 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…
  8. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  9. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  10. 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 …
  11. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …00 1969. 20,399 1970 . 27,988 1971. 63,549 1972. 1,800,274 1973 . 313,863 1974 . 470,495 1975 . 544,895
  12. Court of Appeals for the Eleventh Circuit — Ann Johnson v. Russell Investments Trust Company
    ERISACourt RulingsAug 17, 2026
    … instead . See id. at 1178; s ee also GIW Indus., Inc. v. Trevor, Stewart, Burton & Jacobsen, Inc., 895 F.2d 729, 733 (11th Cir. 1990). When assessing this kind of comparator evidence, we have explained that “ whether an investment is objectively imprudent must be assessed against the actions of a hypothetical prudent …
  13. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  14. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …the following calculation: 6,532 claims × 2 hours × $105.01 + 6,532 claims × 0.5 hour × $55.23 = $1,895,077. 2 × $1,895,077 = $3,790,154. Labor rates are EBSA estimates. Back to Citation 202.  Kaiser Family Foundation. “Surprise Medical Bills: New Protections for Consumers Take Effect in 2022.” (2019).
  15. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …come $2,303,425 $403,869 $2,411,265 $2,286,460 Officers’ compensation 987,554 350,000 1,171,931 940,895 Salaries & wages 148,750 29,167 200,565 303,750 Pension, profit-sharing, plans 46,907 25,000 132,428 169,170 Employee benefit programs -0- -0- -0- -0- Other deductions (VEBA contribution) 480,901 -0- 209,869 296,056 …
  16. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …et does not exist typically for conservation easements. See Symington v. Commissioner, 87 T.C. 892, 895 (1986). C ourts usually value easements indirectly using a “before and after” approach, seeking to determine the reduction in property value attributable to the easement. See Treas. Reg. § 1.170A - 14(h)(3)(i ) . Und…
  17. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
  18. Treas. Reg. § 1.72-7(b)(4) — Adjustment in investment where a contract contains a refund feature.
    IRCRegulationsJul 26, 2016
    …the contract adjusted for the present value of the refund feature without discount for interest $17,895 Example 3.Assume the same facts as in example (1), except that the pre-July 1986 investment in the contract is $10,000 and the post-June 1986 investment in the contract is $11,053. If the annuitant makes the election…
  19. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ax returns. These returns included the following data: 1988 1989 1990 1991 1992 Total income $1,130,895 $1,108,792 $923,488 $114,270 $603,522
  20. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…