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 …
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…
IRCPrivate Letter RulingsOct 17, 2014
in Rev. Ruls. 73-599
and 77-92. Therefore, because Taxpayer does not have any right to a reversion of the existing
retiree life insurance reserve that will be transferred to a retiree health reserve within Trust, such
transfer
will not cause Taxpayer to realize income under section 61 with respect to the balance
attrib…
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…
IRCCourt RulingsJul 6, 2022related by meaning
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 …
IRCPrivate Letter RulingsOct 17, 2014
… a deduction under section 419
for the
taxable year or any prior taxable year.
In Revenue Ruling 73-599, 1973-2 C.B. 40, modified by Rev. Rul. 77-92, 1977-1 C.B. 41, the
issue was whether the
balance in a retired lives reserve had to be included in the gross income
of the
employer in the taxable year in which the emplo…
IRCPrivate Letter RulingsJun 13, 2014
…
section 419 for the taxable year or any prior taxable year.
PLR - 127298-13 6
In Revenue Ruling 73-599, 1973-2 C.B. 40, the issue was whether the balance in a
IRCCourt RulingsAug 3, 1979related by meaning
to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption.
II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
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 RulingsDec 19, 1995★ strong match
…ssue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1995-599
UNITED STATES TAX COURT
RHETT B. ROSS AND SANDRA L. ROSS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4985-93. Filed December 19, 1995.
Paula M. Junghans
, for petitioners.
Alan R. Peregoy…
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…
91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information PBGCProposed Rules (FR)Proposed Jul 21, 2026
…ravating factors.
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
Subpart A—Purpose and Definitions
§ 4071.1
Purpose and scope.
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCCourt RulingsJul 31, 2000
…an paid the first-year premium, and, at the end of
that year, the conversion credit balance was $14,599.19 ($17,390
- $3,419.48 + $628.67); the $628.67 is the interest of 4.5
percent earned on the conversion credit balance (($14,599.19 -
$628.67) x 4.5% = $628.67)). None of the conversion credit
- 37 -
balance could ha…
86 FR 2541 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 13, 2021
… read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,233” are removed and the figures “$2,259” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER…
IRCCourt RulingsAug 22, 1994
…unt that could be accumulated under the principles of Rev. Ruis. 69-382, 1969[ — 2] C.B. 28, and 73-599, 1973-2 C.B. 40. * * * [H. Conf. Rept. 98-861 (1984), 1984-3 C.B. (Vol. 2) 1, 417.]
This quote from the legislative history is relevant for two reasons. First, the conferees again spoke of a “reserve” in terms of an …
77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 30, 2012
…um 2
if monthly
benefit at URA is—
High 3
if monthly benefit at URA is greater than—
From—
To—
2014
599
599
2,531
2,531
2015
611
611
2,582
2,582
2016
623
623
2,633
2,633
2017
636
636
2,688
2,688
2018
649
649
2,745
2,745
2019
663
663
2,803
2,803
2020
677
677
2,861
2,861
2021
691
691
2,922
2,922
2022
706
706
2,983
2,983
…
IRCFinal Rules (FR)Aug 17, 2011
…$0.027. Decreasing the number of paper forms by 6.5 million will save the agency approximately $175,599 per year.
3. Labor
CBP estimates the cost of contractors employed to print the paper courtesy notices is $0.08 per copy. Based on this estimate, the cost savings on labor for printing is approximately $520,294 per ye…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…the unrounded amount per response of $44.225. 104,000 disputes withdrawn × $44.225 per dispute = $4,599,400 total cost.
Back to Citation
290.
This is calculated as follows: 0.25 hours per response × $41.94 hourly rate for an office clerk = approximately $10.49 per response.
Back to Citation
291.
This is calculated us…
85 FR 2304 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 15, 2020
… read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,194” are removed and the figures “$2,233” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER…