145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…s trustee of the Sterling Plan for the benefit of Environmental. The Sterling Plan
treated the $236,667 in payments ($170,639 + $66,028) as employer contributions.
On or after May 15, 2007, Mr. Snyder gave Mr. Tomassetti, on behalf of
Environmental, an annual valuation report showing that the amount of the
allowable co…
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…
IRCRegulationsSep 9, 2016
…he death decrement at age 64 reflected in the funding target for the 2010 plan year is $65,188 ($49,667 + $15,521).(v) Similarly, the portion of the single-sum death benefit for Participant A that is taken into account when determining the target normal cost for 2010 is equal to the sum of the death benefit based on th…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…uction limit is reduced to $200,000 by the $300,000 of AIR for that year and further reduced to $66,667 by the $133,333 of DDR previously attributed to 2017. Because $16,667 does not exceed the $66,667 deduction limit, the $16,667 of DDR is deductible for L’s 2020 taxable year, the year of payment. The deduction limit …
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…
136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner IRCCourt RulingsFeb 7, 2011
… Kleinman in October 2003. At the time of distribution, Schwab's policy had a "policy value" of $48,667 and
Kleinman's had one of $32,576. "Policy value" is an important
term in this case, and it's defined in the plan -documents as
"premiums less policy loads, plus net investment return, less
4 This Notice has been sup…
IRCCourt RulingsJul 8, 1980related by meaning
alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
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…
PBGCFinal Rules (FR)Jul 8, 2022
… an average annual hour burden of 5.07 hours ((7.6+7.6)/3) and an average annual cost burden of $12,667 (($19,000 + $19,000)/3).
The estimated aggregate average annual hour burden for 2022-2024 for the information collection in part 4262 is 1,042.73 hours (780 +23+ 212 + 22.66 + 5.07), which means a cost equivalent of …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ures for all prescription drugs from patients and issuers, less any rebates, totaled approximately $667.0 billion in 2022.[272]
The Department estimates that level-funded and self-insured group health plans account for approximately 16 percent, or $108.8 billion, of these expenditures.[273]
Utilizing the CBO estimates …
IRCCourt RulingsAug 3, 1979related by meaning
istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
IRCCourt RulingsMay 19, 2011
…he airplane as follows:
Year Special depreciation Depreciation Total depreciation
2002 $160,000 $74,667 $234,667
2003 -0- 170,667 170,667
2004 -0- 170,667 170,667
Weekend Warrior also claimed other airplane-related expenses.
Weekend Warrior claimed depreciation with respect to the
boat as follows:
Year Depreciation
200…
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…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…300.
For precision, this is calculated using the unrounded hourly rate, which is approximately $74.667. 0.75 hours × $74.667 hourly rate = $56.00 per issuer/TPA.
Back to Citation
301.
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
IRCCourt RulingsAug 6, 1997related by meaning
Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous,…
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
.
IRCCourt RulingsNov 14, 1996★ strong match
rst articulated.
3
As a
consequence, we set forth that analysis in order to bring into
focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid"
when the letter of credit was purchased on March 13, 1992.
Statutory Framework
The parties have stipula…
IRCCourt RulingsDec 18, 2012related by meaning
…undless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir. 1985), aff'a T.C. Memo. 1984-367.
Respondent did not requ…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…NEW.
Affected Public:
Businesses or other for-profits; not-for-profit institutions.
Respondents:
23,667.
Responses:
23,667.
Frequency of Response:
Annual.
Estimated Total Burden Hours:
5,917.
Estimated Total Costs:
$0.00.
14. Regulatory Flexibility Act
The Regulatory Flexibility Act (RFA) [210]
imposes certain requirem…