91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…Preparation (In-House)
77,012 = 770,117 Plans × 10% Not Using a Service Provider
1
181.06
77,012
13,943,731
Adding Contact and Plan Information to Drafted Explanations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total
138,322
$18,646,718
Table 8—Cost for Distribution of New Paper …
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 RulingsNov 12, 1997
…5 taxable distribution from his law
firm's 401(k) plan; (3) whether petitioner is entitled to a $33,943
interest expense deduction; (4) whether petitioner is liable for an
addition to tax for failure to timely file his 1991 Federal income
t ax return pursuant to section 6651(a)(1); and (5) whethe r
petitioner is liable…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…n ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600.
Back to Citation
210. Annual storage savings of $57,355,200 is calculated by subtracting the total annual cost after file-size reduction ($23,943,600) from the total annual cost under current file-size assumpti…
IRCCourt RulingsJan 14, 2013
…297,798 13,949 311,747
20032 -0- 925,640 1,072 926,712
2004 -0- (917,045) -0- (917,045)
2005 -0- (3,943) -0- (3,943)
Total 16,356,316 519,577 362,091 881,668
1The Court has derived this column of information from the reported taxable
income and depreciation amounts on the Forms 1120.
2The facility was sold in 2002, and…
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…
ERISACourt RulingsAug 14, 2026
…t promised lifetime benefits will indeed survive
for a lifetime.” Stone v. Signode Indus. Grp. LLC , 943 F.3d 381,
385 (7th Cir. 2019) (emphasis in original) ; s ee Tackett, 574 U.S.
at 442 (noting that “a collective-bargaining agreement [may]
provid[e] in explicit terms that certain benefits continue after
the agreement…
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 RulingsMar 9, 2011
…ted dividend income of $100,152, $99,916, and
$80,510 and paid Federal income taxes of $22,063,
$21,943, and $15,349,v respectively. TDH reported
dividend income of $100,152, $99,916, and $80,510 and
paid Federal income taxes of $22,063, $21,943, and
$15,349, respective.ly. TLS reported dividend income of
$100,152, $99…
IRCCourt RulingsOct 21, 2003
…ified individual retirement accounts:
Nationwide Life Insurance Co. $5,000.00
First National Bank 3,943.33
Total distributions $8,943.33
Both institutions issued to petitioner Forms 1099-R,
IRCCourt RulingsMay 29, 1975
…b) was amended by section 1023 of the Employee Retirement Income Security Act of 1974.88 Stat. 829, 943. It now provides: (b) Certain Retroactive Changes in Plan. — A stock bonus, pension, profit-sharing, or annuity plan shall be considered as satisfying the requirements of subsection (a) for the period beginning with …
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…
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 …
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
IRCCourt RulingsAug 24, 1995related by meaning
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
IRCCourt RulingsFeb 28, 2024related by meaning
luded that
the bulk of the $26 million received by hi s IRA was attributable to his
relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
IRCCourt RulingsJun 10, 2002★ strong match
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …