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83 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  2. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …n per respondent (hours) Total annual burden (hours) Total estimated labor cost 2022 1,959 1,959 37,440.0 73,344,960 $10,374,237,120 2023 1,959 1,959 24,440.0 47,877,960 6,611,791,830.97 2024 1,959 1,959 8,060.0 15,789,540 2,180,484,540.00 3 year Average 1,959 1,959 23,313 45,670,820 6,388,837,830.32 Table 9—Estimated …
  3. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …ost Total estimated cost 2021 16,992 16,992 50,976 $5,646,951 $16,992,000 $22,638,951 2022 17,467 2,440,565 3,104,001 116,400,048 828,732 117,228,780 2023 17,467 2,440,565 3,104,001 116,400,048 828,732 183,634 117,228,780 3 Year Average 17,309 1,632,707 2,086,326 79,482,349 6,216,488 85,698,837 Table 10—Annual Burden a…
  4. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
    IRCCourt RulingsDec 24, 1985
    …fore particularly appropriate. Compare National Muffler Dealers Association, Inc. v. United States, 440 U.S. 472, 476 (1979), Helvering v. R. J. Reynolds Tobacco Co., 306 U.S. 110, 114 (1939), and Wang v. United States, 757 F.2d 1000 (9th Cir. 1985), with United States v. Vogel Fertilizer Co., 455 U.S. at 24, Rowan Cos…
  5. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  6. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …s’ partnership interests supports Mr. Ball’s determination that the Property was worth (at most) $1,440,000. We therefore adopt Mr. Ball’s valuation of $1,440,000 as the before value of the Property. 4. Income Approach
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  8. Treas. Reg. § 1.411(b)-1(b)(1)(iii) — Accrued benefit requirements.
    IRCRegulationsSep 9, 2016
    …r the plan (25) and served continuously until normal retirement age (65) is an annual benefit of $1.440 [30 × $48]. Under paragraph (b)(1)(i) of this section, the plan does not satisfy the requirements of this subparagraph unless A has accrued an annual benefit of at least $518 [0.03 × ($1,440 × 12)] as of the close of…
  9. 76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary
    IRCProposed Rules (FR)Proposed Aug 22, 2011
    f disclosures SBC Requirements—Issuers 440 540,000 $18,000,000 $2,900,000 41,000,000 SBC Requirements—TPAs 750 660,000 23,000,000 3,700,000 49,000,000 Coverage Example Requirements—Issuers 440 140,000 7,600,000 1,500,000 41,000,000 Coverage Example Requirements—TPAs 750 240,000 13,000,000 1,800,000 49,000,000 Glossary …
  10. 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…
  11. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  12. 77 FR 8668 — Summary of Benefits and Coverage and Uniform Glossary
    IRCFinal Rules (FR)Feb 14, 2012
    … Hour burden Equivalent cost Cost burden (non-labor) Number of disclosures SBC Requirements—Issuers 440 430,000 $14,000,000 $2,700,000 41,000,000 SBC Requirements—TPAs 750 540,000 18,000,000 3,600,000 49,000,000 Coverage Example Requirements—Issuers 440 59,000 3,300,000 1,400,000 41,000,000 Coverage Example Requirement…
  13. T.C. Memo. 2013-152 — William K. McGraw v. Commissioner
    IRCCourt RulingsJun 17, 2013
    …ly be excluded altogether from gross income. Petitioner recognized, at the time he received the $67,440 check, that a tax-free rollover had not occurred. Rather than implementing a rollover himself by investing the funds in a substitute retirement vehicle, he deposited the money in the bank and used it for general livi…
  14. 62 T.C. 150; 62 T.C. No. 18 — Farley Funeral Home, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1974
    440, and $5,340 in those years, respectively. Petitioner claimed ¿eductions for those amounts on its income tax returns filed for each of those years. On or before March 27, 1972, Treasury Department Forms 2950, “Statement in Support of Deduction” to employees’ pension plan, et al., were filed in behalf of Farley Funer…
  15. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …Sec. 415 limit if no further service Total accrued benefit used by plan’s actuary 1986 $200,000 $32,440 $68,440 $75,000 $32,440
  16. 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…
  17. 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. …
  18. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    arding enforceable claims of the parties; and (ii) the parties' assessments of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable outcomes under the governing instruments and applicable State law. Therefore, based …
  19. 80 FR 54374 — Determination of Minimum Required Pension Contributions
    IRCFinal Rules (FR)Sep 9, 2015
    … 1, 2016, using the first segment rate of 5.26%. See paragraph (c)(2)(ii) of this section. (iii) A $440,298 shortfall amortization base is established for 2016, which is equal to the $2,500,000 funding target, less $1,800,000 of assets, less $259,702 (which is the present value of the remaining four waiver amortization…
  20. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …y 1, 2016, using the first segment rate of 5.26%. See paragraph (c)(2)(ii) of this section.(iii) A $440,298 shortfall amortization base is established for 2016, which is equal to the $2,500,000 funding target, less $1,800,000 of assets, less $259,702 (which is the present value of the remaining four waiver amortization…