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73 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999
    T.C. Memo. 1999-289 UNITED STATES TAX COURT RICHARD DAVID CZEPIEL, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2826-98. Filed August 30, 1999. Richard David Czepiel, pro se. Carmino J. Santaniello , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge : Respondent determined…
  2. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …entertainment $346 $346 --- $346 Travel 401 401 --- 401 Office expenses 677 677 --- 677 Advertising 289 289 --- 289 i. Meals and Entertainment For the reasons explained supra part II(A)(2)(i), petitioners failed to satisfy the substantiation requirements of section 274(d). Accordingly, they are not entitled to a deduct…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  4. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ged 18 to 64 with such conditions in level-funded or self-insured group health plans (see Table 4).[289 290] Research on cost-related non-adherence suggests rates of prescription non-adherence for these conditions among privately insured individuals range from 33 to 37 percent, resulting in approximately 7.7 million pa…
  5. 84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Oct 23, 2019
    Gross Cost Savings [1] 289 290 289 2,821 Costs imposed by the proposed rule: Website 23 16 16 154 Initial Notification and Right to Opt out 90 0 0 90 Notice of Internet Availability 33 17 17 170 Subtotal: Costs of the proposed rule [2] 146 33 32 413 Total Net Cost Savings: [1]-[2] 144 257 257 2,408 Note: Totals in tab…
  6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  7. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…
  8. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  9. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … On May 19, 2017, Mr. Ellison emailed Mr. Berry to inform him that OSI was interested in acquirin g 289 acres of the Parent Parcel. On June 3, 2017, Mr. Kaynard outlined the anticipated structure of the acquisition of 371 acres of the Parent Parcel, instead of 289 acres, in an email to Mr. Ellison. In his email Mr. Kay…
  10. T.C. Summary Opinion 2015-12 — John Sanger Ringbloom v. Commissioner
    IRCCourt RulingsFeb 23, 2015
    …did not. Petitioner testified that after the transfer, Ms. Ringbloom made monthly withdrawals of $2,289 from the IRA, presumably until $38,913 was exhausted. -4The record, however, does not reflect the timing or the amounts of any payments or distributions from the IRA to Ms. Ringbloom. Petitioner made monthly maintena…
  11. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  12. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
  13. 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…
  14. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012★ strong match
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  15. 82 FR 47613 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Oct 13, 2017
    …) On or after Before i1 i2 i3 n1 n2   *         *         *         *         *         *         * 289 11-1-17 12-1-17 0.75 4.00 4.00 4.00 7 8 3. In appendix C to part 4022, Rate Set 289 is added to the table to read as follows: Appendix C to Part 4022—Lump Sum Interest Rates for Private-Sector Payments * * * * * Rate…
  16. 81 FR 47496 — Annual Reporting and Disclosure
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    …0 1.0 1.1 1.9 1,150 1,970 Defined Contribution Pension—Eligible for 5500-SF 580.7 580.7 168.0 188.0 289 324 Defined Contribution Pension—Not Eligible for 5500-SF 25.4 25.4 11.8 33.9 484 1,335 Welfare—Non-Health—Eligible for 5500-SF 0.7 0.7 0.2 0.2 289 324 Welfare—Non-Health—Not Eligible for 5500-SF 3.3 3.3 1.5 2.5 455 …
  17. 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…
  18. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  19. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990
    …ue, Respondent Estate of Levitt v. Commissioner Docket No. 28680-88 United States Tax Court 95 T.C. 289; 1990 U.S. Tax Ct. LEXIS 87; 95 T.C. No. 22; September 13, 1990, Filed *87 Decision will be entered under Rule 155. On June 12, 1975, D executed a trust agreement and made an inter vivos transfer of certain property …
  20. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …, allow those who experience infertility a potential path to expand their families.[32] In 2022, 98,289 infants born (or about 2.7% of all infants born) in the United States were conceived through the use of ART.[33]