Search the Pension Law Library

1. 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…
2. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
   IRCCourt RulingsMay 3, 1995
   …ng amounts: Deductions Contributions Year Claimed Cumulative Paid Cumulative Difference 1983 $1,725,684 $1,725,684 -0- -0- $1,725,684 1984 1,451,184 3,176,868 $768,305 $768,305 2,408,563 1985 1,007,903 4,184,771 879,700 1,648,005 2,536,766 Deductions Contributions Year Claimed Cumulative Paid Cumulative Difference -0-4…
3. 79 FR 13949 — Amendment Relating to Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
   ERISAProposed Rules (FR)Proposed Mar 12, 2014
   …that there are 2.2 million covered arrangements between 12,000 covered service providers and nearly 684,000 covered plans for which disclosures are required under the final rule. While some of these arrangements are simple, others are complex and would require much information to be disclosed. The Department is not awa…
4. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
   IRCCourt RulingsSep 24, 2007related by meaning
   )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
   IRCCourt RulingsJul 31, 2000★ strong match
   …d, at the end of that year, the conversion credit balance was $15,903.15 ($19,004.55 - $3,786.22 + $684.82); the $684.82 is the interest of 4.5 percent earned on the conversion credit balance (($15,903.15 - $684.82) x 4.5% = $684.82)). None of the conversion credit balance could have been transferred at this time to th…
6. 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…
7. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
   IRCCourt RulingsJan 14, 2013
   …7,264 12,923 (5,659) 1984 29,955 6,000 ! 23,955 6,968 -0- 6,968 -26- [*26] 1983 28,899 -0- 28,899 6,684 -0- 6,684 1982 27,881 -0- 27,881 6,412 -0- 6,412 1981 26,899 -0- 26,899 6,151 -0- 6,151 1980 25,952 -0- 25,952 5,900 -0- 5,900 1979 25,037 -0- 25,037 5,660 -0- 5,660 1978 24,155 -0- 24,155 5,429 -0- 5,429 1977 23,304…
8. T.C. Summary Opinion 2005-112 — James M. & Mary N. Gorski v. Commissioner
   IRCCourt RulingsAug 4, 2005
   …isting of tuition, fees, and room and board. Petitioners argue that additional expenses totaling $2,684.30 are also qualified higher education expenses and should not be subject to the 10-percent additional tax. The disputed $2,684.30 is made up
9. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   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 …
10. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022★ strong match
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
11. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    IRCCourt RulingsDec 29, 2008
    …0, except for 1996 where they had a refund due . The total amount due, including additions, was $48,684 . On behalf of the Martinezes the law firm prepared an offer-in-compromise, offering $1,000 to settle the entire debt . The firm submitted the offer to the IRS during the summer of 2001 after Mr . Martinez's death in…
12. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …sponses Burden hours per respondent Total burden hours Total cost 1,959 23,508 372 728,748 $106,326,684.00 The Departments estimate the total one-time year one burden for all issuers and TPAs will be 15,178,332 hours, with an associated equivalent cost of approximately $2,024,117,160 to develop and build the In-network…
13. 29 T.C. 22 — Loeb v. Commissioner
    IRCCourt RulingsOct 11, 1957
    …h was given to her by Clarence. On the day she opened the account she drew three checks totaling $1,684.30 to pay the initial premiums on the Prudential, Home Life, and John Hancock policies. Subsequent premium payments to the insurance companies with respect to the above policies were made by checks drawn upon this ac…
14. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
15. T.C. Memo. 1996-212 — Louis R. & Gregoria S. Gomez v. Commissioner
    IRCCourt RulingsMay 1, 1996related by meaning
    n annuity payment. Discussion Respondent determined that, based on the exclusion ratio calculated pursuant to section 72(b), petitioners were required to include a portion of the lump-sum payment from petitioner’s CSRS in their gross income in 1987. Petitioners argue that such inclusion would result in double taxation …
16. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    ven report the distributions. the clear intent of Congress to prevent voluntary withdrawals, we decided that the penalty was inapplicable. Id. at 291. Petitioners’ reliance on Larotonda v. Commissioner , supra , is misplaced. Here, respondent did not levy on the retirement accounts. Petitioners made voluntary withdrawa…
17. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    … for decision is whether and to what extent, if any, Parker-Hannifin Corporation may deduct $32,498,684 in contributions it made to a welfare benefit trust on June 30, 1987.
18. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    tz v. Commissioner , supra , and Kasey v. Commissioner , supra , is also misplaced. In those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and remitted to judgment creditors. In neither case is there any indication that the taxpayers disputed their …
19. 82 T.C. 608; 82 T.C. No. 48 — Connelly v. Commissioner
    IRCCourt RulingsApr 18, 1984related by meaning
    .e., the amount received under the Act in excess of the amount contributed to the retirement program by taxpayer is taxable income. [326 F.2d at 968.] We note that the Commissioner has acknowledged that a Civil Service employee who resigns and later reenters Civil Service employment and who elects to repay to the U.S. …
20. DOL Office of Administrative Law Judges — USDOL, EBSA v. PLAN ADMINISTRATOR, HOME OF ECONOMY 401(K) PLAN, HOME OF ECONOMY, INC.
    ERISACourt RulingsJun 26, 2013
    …of Labor Office of Administrative Law Judges 36 E. 7th St., Suite 2525 Cincinnati, Ohio 45202 (513) 684-3252 (51 3) 684-6108 (FAX) Issue Date: 26 June 2013 Case Nos.: 2010 - RIS - 00013 2012 - RIS - 00113 2012 - RIS - 00114 In the Matter of: UNITED STATES DEPARTMENT OF LABOR, EMPLOYEE BENEFITS SECURITY ADMINISTRATION, …