89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…rs. The equivalent cost is estimated as: 1 automatic portability provider × 10 hours × $159.34 = $1,593.40, rounded to $1,593.
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157.
The hour burden is estimated as: 185,000 plans × 2/60 hours = 6,167 hours. The equivalent cost is estimated as: 185,000 plans × 2/60 hours × $63.45 = $391,275.
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89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
023).
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696.
This is estimated as: 114,931,000 × 38.8% ≉ 44,593,228.
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697.
In 2023, there were 67,781,000 IRAs. (
See Cerulli, The Cerulli Report, U.S. Retirement End-Investor 2023, Exhibit 5.12, (2023)).
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698.
The number of plan participants receiving paper disclosures…
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 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
IRCCourt RulingsJun 4, 1997★ strong match
…hy v. Commissioner
, 87 T.C. 56, 64 (1986);
Schuster's Express, Inc. v. Commissioner
, 66 T.C. 588,
593 (1976), affd. per curiam 562 F.2d 39 (2d Cir.
1977); Rubin v. Commissioner
, 56 T.C. 1155, 1163
(1971), affd. 460 F.2d 1216 (2d Cir. 1972). "Fair
warning means that respondent's failure to give
petitioner notice of […
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 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 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 17, 2026
…nsider and weigh competing evidence. See, e.g., Daubert v. Merrell
Dow Pharms., Inc., 509 U.S. 579, 593 (1993) ; United States v. Robelo -
Galo , 166 F.4th 1311, 1316 (11th Cir. 2026). To that end, in Pizarro ,
IRCCourt RulingsMay 9, 1988★ strong match
e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted.
An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
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 RulingsJan 16, 2020related by meaning
bed in section 72(t) in respect of Mr. Merrell's IRA
distribution is sustained.
As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case.
We have considered similar claims in the past and have observed that there is no
-8au…
IRCCourt RulingsDec 18, 2012
…etitioners' gross income for the subject years includes interest
income of $480, $231, $148, $798, $593, and $653, respectively. We hold that it
does;
4. whether petitioners' gross income for the subject years includes
"unreported income" of $11,122, $22,520, $8,502, $155,523, $110,720, and
$88,965, respectively.5 We h…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
hat will have a selected a certified IDR entity, the annual burden would be 4,593 hours, with an annual equivalent cost estimate of $0.4 million.[258] The Departments assume that 5 percent of notices would be mailed and will incur a printing cost of $0.05 per page and $0.55 for postage. Thus, the mailing cost is estima…
IRCCourt RulingsSep 29, 1987
… his intention to proceed under that theory. Schuster’s Express, Inc. v. Commissioner, 66 T.C. 588, 593 (1976), affd. per curiam 562 F.2d 39 (2d Cir. 1977); Rubin v. Commissioner, 56 T.C. 1155, 1163 (1971), affd. 460 F.2d 1216 (2d Cir. 1972). Fair warning means that respondent’s failure to give petitioner notice of his…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
… 1985 final rule (50 FR 3892, 3895-96 (Jan. 29, 1985)).
See also Bechtel
v.
PBGC,
624 F. Supp. 590, 593 (D.D.C. 1984), aff'd,
Bechtel
v.
PBGC,
781 F.2d 906, 907 (D.C. Cir. 1986).
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2.
Bechtel
v.
PBGC,
781 F.2d 906, 907 (D.C. Cir. 1986).
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3.
Id.
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4.
IRCPrivate Letter RulingsAug 27, 1999
…ed as preventing accrual. As the Court noted in United States v. Hughes
Properties, Inc. , 476 U.S. 593, 605-606 (1986):
There is always the possibility, of course, that a casino may go out of
business, or surrender or lose its license or go into bankruptcy, with the result
that the amount shown on the jackpot indicato…