IRCCourt RulingsAug 25, 1997
T.C. Memo. 1997-389
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed August 25, 1997.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was ass…
IRCCourt RulingsMar 31, 1961★ strong match
…al cost of pension, as adjusted, as of Jan. 1, 1954_ $14, 940. 86
Amount to be received annually_$5,389.44
Number of years for which payment is guaranteed ($47,887.09 divided by $5,389.44)_years— 9
Percentage provided by actuarial table III for age 72 and 9 years guaranteed payments_percent— 21
Subtract value of the re…
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…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…
materials cost
Total estimated
cost
2021
879
879
3,077
$349,622
0
$349,622
2022
879
25,398,998
279,389
10,857,056
838,167
11,695,223
2023
879
25,398,998
279,389
10,857,056
838,167
11,695,223
3 year Average
879
16,932,958
187,285
7,354,578
558,778
7,913,356
10. Summary of Annual Burden Estimates for Information Collect…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…Department estimates that the value of the gross consumer willingness to pay would result in up to $389.6 million of benefits annually.[317]
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 RulingsFeb 15, 2002
…d income retirement program similar to a sec. 401(k) plan.
4
The amount of the distribution was $30,389.94.
Respondent agrees that only $27,389 was taxable.
Federal income tax and an addition to tax under section
6651(a)(1) of $4,398 and $660, respectively. The issues are:
(1) Whether a distribution from a retirement p…
IRCCourt RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
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 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…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
… and best use of the property on the
valuation date. Stanley Works & Subs. v. Commissioner, 87 T.C. 389,
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
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 RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
…ity
Cost burden
(A)
(B)
(A × B)
(C)
(A × B × C)
(D)
(A × D)
Service providers prepare information
389
1
389
$121.53
$47,235
Participants receiving notices for exemption through mail, prepared by service providers
24,500
0.03
817
65.99
53,892
$0.78
$19,110
Total
24,889
1,205
101,126
19,110
Summary
Please see Table 7 f…
IRCCourt RulingsAug 24, 1981related by meaning
in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…f assets
1
--- 9,827,240 16,953,743 33,112,945
F. Present value future normal costs
2
39,673,488 65,389,545 93,638,363 99,428,929
G. Average present value of future service 4.81 6.63 7.26 7.19
H. Normal cost (beginning of year)
3
8,248,126 9,862,676 12,897,846 13,828,780
I. Benefits paid during year N/A 4,078,160 4,859…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
IRCCourt RulingsApr 12, 1979related by meaning
e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ell v. United States, 267 U.S.
341, 344 – 45 (1925); Stanley Works & Subs. v. Commissioner, 87 T.C.
389, 400 (1986); Treas. Reg. § 1.170A - 14(h)(3)(ii). A property’s highest
and best use is the most profitable use that is legally permissible,
physically possible, financially feasible, and maximally productive.
Olson v…