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86 documents · 0.46sAllIRCERISAPBGCJoint Board
  1. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …lves or their partner to become pregnant.[152] As such, the Departments estimate that approximately 743,361 participants or beneficiaries in non-Federal employer-sponsored health plans aged 25 to 45 would seek medical assistance to become pregnant each year.[153] The Departments estimate an equal share would likely enr…
  2. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  4. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019
    …mmissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); see also Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). In order for the Court to estimate the amount of a deductible expense, the taxpayer must establish some basis upon which an estimate may be made. Norgaard v. Commissioner, 939 F.2d 874, 879 (9th Cir. 1991), a…
  5. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    … estimated labor Cost 2020 1,959 1,959 2,508 4,913,172 $432,996,203 2021 1,959 1,959 145 284,055 25,743,023 2022 1,959 1,959 145 284,055 25,743,023 3 year Average 1,959 1,959 933 1,827,094 161,494,083 Table 7—Estimated Low-End Three Year Average Annual Hour Burden and Costs for All Health Insurance Issuers and TPAs To …
  6. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  7. 81 FR 25540 — Suspension of Benefits Under the Multiemployer Pension Reform Act of 2014
    IRCFinal Rules (FR)Apr 28, 2016
    guarantee payable by PBGC, which is $743.75 after normal retirement age ($29.75 × 25 years = $743.75). (iv) Calculation of guarantee-based limitation. A suspension of benefits may not reduce the participant's benefits, determined on and after the effective date of the suspension, below the guarantee-based limitation, w…
  8. 80 FR 35262 — Suspension of Benefits Under the Multiemployer Pension Reform Act of 2014
    IRCProposed Rules (FR)Proposed Jun 19, 2015
    guarantee payable by PBGC, which is $743.75 after normal retirement age ($29.75 × 25 years = $743.75). (iv) Calculation of guarantee-based limitation. A suspension of benefits may not reduce the participant's benefits below the guarantee-based limitation, which is equal to 110% of the monthly amount of guarantee payabl…
  9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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 …
  10. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  11. 88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCProposed Rules (FR)Proposed Nov 20, 2023
    …rship interests, such as adjustments under section 734(b) of the Code and adjustments under section 743(b) of the Code. Section 755(a) generally provides that any increase or decrease in the adjusted basis of partnership property under section 734(b) (relating to the optional adjustment to the basis of undistributed pa…
  12. Treas. Reg. § 1.432(e)(9)-1(d)(2)(v) — Benefit suspensions for multiemployer plans in critical and declining status.
    IRCRegulationsSep 9, 2016
    …BGC guarantee formula is then applied to produce the amount of guarantee payable by PBGC, which is $743.75 after normal retirement age ($29.75 × 25 years = $743.75).(iv) Calculation of guarantee-based limitation. A suspension of benefits may not reduce the participant's benefits, determined on and after the effective d…
  13. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  14. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  15. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …47,539,329 D. Nondeductible contribution from prior years (O from prior year) --- 22,034,781 14,394,743 14,426,384 E. Net value of 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 7.1…
  16. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  17. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  18. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010★ strong match
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  19. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    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…
  20. 89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCFinal Rules (FR)Jun 28, 2024
    … Code. Rev. Rul. 87-115 concludes that, in addition to the upper-tier partnership computing section 743(b) adjustments and allocating them among its properties under section 755, an interest in the lower-tier partnership will be deemed to have been transferred for purposes of the lower-tier partnership computing sectio…