167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
… nearly identical to the DCF
5
The parties have stipulated that the after value of the Property is $640,000
and that petitioner i s entitled to a noncash charitable contribution deduction of
$640,000 for the donation of the fee simple interest .
18
analysis included in the June Blethen Report. The December Blethen
Repo…
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…
75 FR 5410 — Interim Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 IRCFinal Rules (FR)Feb 2, 2010
…age annual dollar limit that can be applied to mental health or substance use disorder benefits is $640,000 (40% × $100,000 + 60% × $1,000,000 = $640,000).
(c)
Parity requirements with respect to financial requirements and treatment limitations
—(1)
Clarification of terms
—(i)
Classification of benefits.
When reference…
IRCCourt RulingsJun 18, 1999★ strong match
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
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…
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
…VI. CORRECTION ON AUDIT (AUDIT CAP)
SECTION 13. DESCRIPTION OF AUDIT CAP
.01 Audit CAP requirements
640
.02 Payment of sanction
640 .03 Additional requirements
640
.04 Failure to reach resolution
640
.05 Effect of closing agreement
640
.06 Other procedural rules
640
SECTION 14. AUDIT CAP SANCTION
.01 Determination of s…
77 FR 8668 — Summary of Benefits and Coverage and Uniform Glossary IRCFinal Rules (FR)Feb 14, 2012
…TPA
Hours
Equivalent cost
Hours
Equivalent cost
Hours
Equivalent cost
IT Professionals
$54.52
30
$1,640
30
$1,640
30
$1,640
Benefits/Sales Professionals
43.76
30
1,310
30
1,310
30
1,310
Financial Managers
78.50
10
780
10
780
10
780
Attorneys
86.86
10
870
10
870
10
870
( printed page 8692)
Total per issuer/TPA
80
4,600
…
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…
IRCRegulationsJul 26, 2016
…ear is $794.70 ($12,000 ÷ 15.1), and the post-June 1986 investment in the contract so allocable is $640.39 ($13,000 ÷ 20.3). Because the applicable portions of the total payment received in 1991 under the contract ($480 allocable to the pre-July 1986 investment in the contract and $520 allocable to the post-June 1986 i…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCCourt RulingsJan 3, 2011
…otect-ion should be calculatedebyyaddingethe inortality charges
($8 4296) ,and othera expenses ($2, 640) . The sum of $11;136 reflects the -charges zfore currentayearolifeminsurance: that were
already subtractedyfrom theefair market value calcu]:ation : 4
determineduusing-the PERCuamount, pursuant to Reve Proc-. 2005/2…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
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 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 RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
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…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…clared by BI
and paid in cash to GSI by BI:
Fiscal year
Dividends declared
Amount paid
3/31/79 $310,640 $310,640
3/31/80 524,888 524,888
3/31/81 489,426 489,426
6/30/81
1
169,440 169,440
1982 1,613,012 1,613,012
1983 204,740 204,740
1984 420,070 420,070
1985 388,300 388,300
1986 76,248 76,248
1987 105,900 105,900
1988 …
IRCCourt RulingsAug 8, 1996related by meaning
…ioner argues that we should abate the interest
determination made by respondent pursuant to section 6404(e)
because of respondent's delay in issuing the notice of
deficiency. The United States Tax Court is a court of limited
jurisdiction. See sec. 7442; Wilt v. Commissioner
, 60 T.C. 977,
978 (1973). New section 6404(g…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
… in fact, approximately two-thirds of households participating in a pension plan do not own an IRA.[640]
This rulemaking will require advice given to the plan fiduciaries to meet a fiduciary standard, resulting in improvements in plan design and selection of investments on the menu that will benefit small savers as the…
REG-148326-05 — Proposed regulations address the calculation of amounts includible in income under section 409A(a) of the Code and the additional taxes imposed by such section… IRCProposed Rules (FR)Proposed Dec 22, 2008
…sing total amount (590), plus the amounts paid during Year 4 that were includible in income (50) or 640. To calculate the premium interest tax, the 640 must be allocated to the year or years in which the amount was first deferred and vested.
(ii) Step A. Identification of vested total amount deferred excluding payments…