IRCCourt RulingsJan 30, 2007
…. 2005-176.
The Plan 15104 Form W-2 reflects a gross distribution to
petitioner from Plan 15104 of $372,850 and that petitioner made no employee contributions to Plan 15104. The parties stipulated
the accuracy of the Plan 15104 Form W-2, and no evidence in the
record contradicts the Plan 15104 Fórm W-2. This evidence, …
IRCCourt RulingsMar 5, 1987
… and continues to perform judicial services as he is willing and able to do so. Pursuant to section 372(a) of the Judicial Code, an article III judge who is permanently disabled and has served at least 10 years may retire and continue to receive the salary of the office for the rest of his life, and an article III judg…
IRCCourt RulingsJul 13, 2017
…e consequences that
might result from a win or loss of a legal claim. See United States v. Gilmore, 372
U.S. 39 (1963); Kenton v. Commissioner, T.C. Memo. 2006-13, 2006 WL
237112; Test v. Commissioner, T.C. Memo. 2000-362, 2000 WL 1738858, aff'd,
49 F. App'x 96 (9th Cir. 2002).
In Test v. Commissioner, 2000 WL 1738858,…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…per format. As Table 11 shows, the Department estimates the proposed rule, if finalized, will save $372 million in the first year and $395 million in subsequent years.
1. Rule Familiarization and Compliance Costs
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 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
IRCCourt RulingsJun 17, 1997
…inancial Benefits
Trust" (E.I.N. 86-6184818):
10
1990
1991
1992
1993
1994
Interest income $232,158 $372,992 $351,722 $106,927 $92,464
Other income: forfeitures --- 9,453 --- --- ---
Other income: refund trustee fees --- --- --- --- 4,012
Tax exempt income 55,467 34,812 295,340 118,797 14,498
Total income 232,158 382,44…
IRCCourt RulingsFeb 21, 2012
…NDUM FIND NGS OF FACT A OPINION
COHEN, Judge: Respondent d±termined deficiericies of $15,635 and
$2,372 in petitioner's Federal income taxes for 2005 and 2d06, respectively.
<
SE8vED FEB 2 1 2012
- 2 -
Respondent also determined additions to tax under sections 6651(a)(1) for each
year and a penalty under section 6662(a…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsSep 18, 2018
…
which it treated as tax-deductible expenses of the medical practice:
Date Contribution
11/14/2006 $372,446
12/05/2007 372,446
10/08/2008 372,486
11/19/2009 372,485
10/27/2010 372,486
Total 1,862,349
During 2007-2012 the Legacy Trust (and later the Flex Trust) paid premiums on the Policy as follows:
D_ate Premium paid
…
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 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…
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…s, and Optum Rx respectively reported $162.5 billion,[370]
$185.4 billion,[371]
and $133.2 billion [372]
in revenue in 2024, according to the SEC 10-k filings. Even for “small” PBMs, the Department expects that annual receipts would not be significantly below the SBA threshold and that few PBMs have annual receipts lev…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsNov 28, 2001
…n
lists the $11,747 Denso Plan distribution as taxable income, in
addition to $22,168 of wages and $372 of unemployment
compensation. Petitioner’s 1997 tax return also shows total
Federal income tax withheld of $5,807.
2
- 4 -
3
As previously stated, the actual amount of taxable wages
shown on petitioner’s 1997 tax ret…
IRCCourt RulingsMay 19, 2011related by meaning
b) (2) and 72. See Chevron U.S.A.
Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842-843
(1984).
II. Application of Sections 402(b) (2) and 72 Because we have found that section 402(b) (2) controls the
tax consequences of the policy distributed to petitioners, -we now
turn our attention to that section to deter…
IRCCourt RulingsJan 13, 1999related by meaning
tions. Sec. 72(t)(3)(A).
or after the death of the employee; (3) attributable to the
employee's being disabled within the meaning of section 72(m)(7); (4) part of a series of substantially equal periodic payments
(not less frequently than annually) made for the life (or life
expectancy) of the employee or joint lives (…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
…n from the clear reflection of income
principle, citing H.R. Rep. No. 77- 2333 (1942), 1942- 2 C.B. 372, 452, and
S. Rep. No. 77- 1631 (1942), 1942- 2 C.B. 504, 609. We agree with
respondent.
In Jacobs, 45 T.C. at 135, this Court stated that section 404(a)(5)
removes arrangements from the normal rules of tax accounting…