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…
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…
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 …
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…
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…
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. …
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).…
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 …
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…
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…
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…
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…
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 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…
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…
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
…
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…
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.
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 …
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]