IRCCourt RulingsJul 14, 2005★ strong match
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…
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975
… by April 30, 1972, the final day of its taxable year 1972; and (2) whether the contribution of $19,759.25 made by petitioner to the profit-sharing trust on July 13, 1972, was deductible on petitioner’s corporate income tax return for its taxable year 1972.
All of the facts have been stipulated and the stipulation of f…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ilding pad to the average
building pad size of 43, 996 square feet yields an indicated value of
$ 1,759,840 per lot .
ii) Price p er Lot
Mr. Williams and Mr. DuVall estimated the value of the northern
IRCCourt RulingsJul 31, 2000
end of that year, the
conversion credit balance was $17,643.01 ($8,603.71 + $10,530 -
$2,250.45 + $759.75); the $759.75 is the interest of 4.5 percent earned on the conversion credit balance (($17,643.01 - $759.75) x
4.5% = $759.75)). Of the conversion credit balance, $8,380.43
could have been transferred at this time …
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…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…rement medical benefits for active employees to
be $ 14,096,473 and for retired employees to be
$27,759,057. The actuary divided the $14,096,473 for
active employees by the average actuarial present value
o f future service to produce a 1991 funding amo unt of
$2,930,660 for active employees. The actuary determined
tha…
IRCCourt RulingsFeb 9, 2023★ strong match
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsJun 20, 2001
…now concedes that
$23,845.64 is nontaxable or was reported in income by petitioner
in that year: $3,759.27 (taxable distribution from retirement
money market account included in taxable distribution reported by
petitioner); $15,297 (Aug. 3, 1995, workers’ compensation
settlement payment); $180 of $1,363.42 deposit made…
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 RulingsOct 8, 2003related by meaning
ng this amount. Subsequently,
J.D. merged into Clarkston pursuant to section 368, and filed a
final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the
final return year of J.D. eliminated by book entry as a result of
the merger.
- 5 -
Discussion
Respondent’s …
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsNov 8, 1976related by meaning
n changing its name.
Decision will be entered for the respondent in docket No. 6797-74.
Decision will be entered under Rule 155 in docket No. 6798-74. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
Mr. Hebert is excluded from the computation because his salary …
IRCCourt RulingsJun 29, 2015
… y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 26476-12, 756-13, Filed June 29, 2015.
759-13, 777-13,
779-13.
Neal J. Block, Robert S. Walton, John T. Bender, and Rebecca Lock, for
petitioners.
John Q. Walsh, Jr., Sarah S. Sandusky, and Peter N. Scharff, for respondent.
¹Cases of the following petitioners…
IRCRegulationsSep 9, 2016
…852 per month for survivor annuity) Approximately the same value as the Life Annuity. Lump sum $135,759 Approximately the same value as the Life Annuity. (ii) In accordance with paragraph (d)(4)(i) of this section, when Participant M requests specific information regarding the amounts payable under the QJSA, the joint …
82 FR 60308 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 20, 2017
…693
693
2,927
2,927
2023
709
709
2,995
2,995
2024
725
725
3,064
3,064
2025
742
742
3,134
3,134
2026
759
759
3,206
3,206
2027
777
777
3,280
3,280
2028 or later
794
794
3,355
3,355
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington, DC, by:
Daniel S. Liebman,
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…ds through June 1, 2000 (that is, $750 for March 31, 1998 to December 31, 1998, $575 for 1999, and $759 for January 1, 2000 to June 1, 2000) is allocated to Employee X. Accordingly, Employer L makes a contribution on June 1, 2000 to the plan of $7,084 ($5,000(1.15)(1.10)(1.12)). Employee X’s account balance as of Decem…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…mation to Drafted Explanations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total
138,322
$18,646,718
Table 8—Cost for Distribution of New Paper Benefit Statements for 2020 Safe Harbor
[Year 1]
Description
Affected entities
Pages per
disclosure
Material costs per
page
Distribution
…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…ds through June 1, 2000 (that is, $750 for March 31, 1998 to December 31, 1998, $575 for 1999, and $759 for January 1, 2000 to June 1, 2000) is allocated to Employee X. Accordingly, Employer L makes a contribution on June 1, 2000 to the plan of $7,084 ($5,000(1.15)(1.10)(1.12)). Employee X’s account balance as of Decem…