IRCCourt RulingsMar 24, 1993
…ant or division, to suggest that a partial termination has occurred. In re Gulf Pension Litigation, 764 F. Supp. at 1168; Morales v. Pan Am. Life Ins. Co., 718 F. Supp. at 1302-1303, and cases cited therein. A drop of less than 20 percent has been considered significant only if accompanied by egregious abuse on the par…
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 31, 2000★ strong match
…nd,
at the end of that year, the conversion credit balance was $40,969.07 ($48,680 - $9,475.15 + $1,764.22); the $1,764.22 is
the interest of 4.5 percent earned on the conversion credit
balance (($40,969.07 - $1,764.22) x 4.5% = $1,764.22)). None of
the conversion credit balance could have been transferred at this
time…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…%
($100)
0.021%
($126)
From 0.000% to 0.001%.
(From $1 to $6).
Plans with 6-10 Participants
153,541
764,808
0.013%
($102)
0.013%
($100)
0.017%
($126)
From 0.001% to 0.002%.
(From $6 to $13).
Plans with 11-20 Participants
158,608
1,086,263
0.009%
($102)
0.009%
($100)
0.012%
($126)
From 0.001% to 0.002%.
(From $12 to $25…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsJan 14, 2013
…s:6
Year Ms. Fletcher Dr. Fletcher
1973-1983 -0- -01984 $6,000 -01985 13,000 $12,923
1986 15,521 18,764
1987 26,769 29,077
1988 36,000 36,000
1989 36,000 36,000
1990 4,154 4,154
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968★ strong match
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
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…
IRCCourt RulingsJul 25, 2023
…ioner was employed by the N ew York City
Transit Authority. For that year it paid him wages o f $80,764, reporting
that amount to him on Form W – 2, Wage and T ax Statem ent . He does
not dispute that he received wages of $80,764 during 2018.
During 2018 petitioner received from the New York C ity Retirement Systems Tr…
IRCCourt RulingsSep 25, 1996
…and MPC under
the employee leasing agreement. The Termination Agreement stated
that MPC owed $2,148,764 to MIT 83 under the leasing agreement
(the $2,148,764 amount is an error; the amount that should have
appeared in the Termination Agreement was $2,135,260), and that
MPC offered to pay $1,899,633. MPC proposed to do …
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
Atkins, Judge:
The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…
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 RulingsOct 16, 2001related by meaning
hin the taxable year
in carrying on a trade or business or an activity described
in section 212 (relating to expenses for production of
income). * * * Section 164(a) does not mention Federal income taxes. On
the other hand, section 275(a)(1) provides, inter alia, that no
deduction shall be allowed for Federal income ta…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
… self-pay) individuals and providers and facilities is 255,524 hours with an equivalent cost of $29,764,646, as shown in Table 48.[304]
HHS invites comment on the assumptions and calculations made in this ICR.
Table 48—Annual Burden and Cost Related to Patient-Provider Dispute Resolution Process for Uninsured (Self-Pay…
IRCCourt RulingsMay 9, 1988related by meaning
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 20, 1976related by meaning
ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment.
SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
79 FR 66617 — Revisions to Annual Return/Report-Multiple-Employer Plans ERISAFinal Rules (FR)Nov 10, 2014
…g, the Department estimates that 5,527 multiemployer plan administrators will spend approximately 2,764 hours complying with the CSEC Act requirements at an equivalent cost of approximately $173,000 (2,764 hours times $69 for the
( printed page 66621)
services of an in-house financial professional).[5]
The OMB emergenc…
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…