IRCCourt RulingsJun 17, 1996
…at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1996-278
UNITED STATES TAX COURT
DONALD G. RUSSELL, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12946-95. Filed June 17, 1996.
Donald G. Russell, pro se.
Gary W. Bornholdt
, for respondent.
MEMORAND…
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 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 RulingsMar 6, 2001
…suffer undue damage by imposition of
- 26 -
the liability.’” Purer v. United States
, 872 F.2d 277, 278 (9th
Cir. 1989) (quoting Wagner v. Director, Fed. Emergency Mgmt.
Agency
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…74
2021
116,709 * (Additional burden for Subset of Physicians with Websites)
* 116,709
1
116,709
13,278,038
Total
3.5
481,426
** 75,075,712
* This is calculated as the sum of $61,797,674 (cost for all individual physician practitioners to draft notice of right to GFE) + $13,278,038 (cost for computer programmers to pos…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…6 (6th Cir. 2022);
see also Matousek
( printed page 16091)
v.
MidAmerican Energy Co.,
51 F.4th 274, 278 (8th Cir. 2022) (noting that for the duty of prudence, “[t]he process is what ultimately matters”). Thus, prudence is assessed based on a fiduciary's investigation at the time of the investment decision, and not in h…
IRCCourt RulingsAug 28, 2014
…ldren.
II. Retirement Account Loan and Distributions Sometime before 2011 Mr. Matthews borrowed $36,278 from his 401(k)
plan account. During 2011, shortly after losing his job with Synapse,
Mr. Matthews requested a distribution of $128,140 from his 401(k) plan account.
He understood that his loan would have to be repai…
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 …
IRCCourt RulingsFeb 29, 2012★ strong match
…e to be taken as the final expression of the
meaning intended." United States v. Mo. Pac. R.R. Co., 278 U.S. 269, 278 (1929).
Thus we look to the specific language of the statute to determine whether it is
clear and unambiguous.
Both respondent and petitioner argue that section 4980(c)(1)(A) is clear and
unambiguous. H…
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…
81 FR 80002 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Nov 15, 2016
…)
On or
after
Before
i1 i2
i3
n1
n2
* * * * * * *
278
12-1-16
1-1-17
0.75
4.00
4.00
4.00
7
8
( printed page 80003)
3. In appendix C to part 4022, Rate Set 278, as set forth below, is added to the table.
Appendix C to Part 4022—Lump Sum Interest Rates For Private-Sector …
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…
IRCRegulationsSep 9, 2016
…000 Net adjustments: 1988 40,500 40,500 40,500 1987 38,500 38,500 1986 44,500 Total 273,500 275,500 278,500 228,000 Average value: 1988 = $273,500 + $275,500 + $278,500 + $228,000 ÷ 4 = $263,875 (ii) Plan F properly determines an average value under paragraph (b)(7) of this section for use as an actuarial value. Theref…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
278” and paragraph (b)(2) by removing “$54,910” and adding in its place “$55,808”.
PART 578—MINIMUM WAGE AND OVERTIME VIOLATIONS—CIVIL MONEY PENALTIES 17. The authority citation for part 578 continues to read as follows:
Authority:
Sec. 9, Pub. L. 101-157, 103 Stat. 938, sec. 3103, Pub. L. 101-508, 104 Stat. 1388-29 (2…
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 RulingsAug 10, 2015
…l of
petitioner's deductions should be disallowed.
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Dagres v. Commissioner, 136 T.C. 263, 277-278 (2011); see also Papineau v.
Commissioner, 28 T.C. 54, 57 (1957). New matter includes a new theory that
"'alters the original deficiency or requires the presentation of different evidence.'"
Dagres v. Commissioner, 1…