T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…rtion average 8.7 acres in gross area with an average building pad of
approximately 1.02 acres (4 3,996 sf).
32
Th ese lots are generally larger
than the lots emphasized by petitioner’s experts and smaller than
several lots emphasized by respondent’s expert. N one of the appraisal
experts provided consistent quantitati…
IRCCourt RulingsJan 14, 2013
…8 24,155 -0- 24,155 5,429 -0- 5,429
1977 23,304 -0- 23,304 5,208 -0- 5,208
1976 22,484 -0- 22,484 4,996 -0- 4,996
1975 21,691 -0- 21,691 4,792 -0- 4,792
1974 20,927 -0- 20,927 4,597 -0- 4,597
1973 20,190 -0- 20,190 2,205 -0- 2,205
Total 1,068,923 512,985 555,938 558,053 315,699 242,354
For the years for which a "-0-" a…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ebcast_pptx.pdf.
Back to Citation
58. The burden is estimated as: [(395 small broker-dealers + (2,996 small registered-investment advisers × 8%) + 151 small insurers + 10 small robo-advisers + 930 small pension consultants + 20 small investment company underwriters) × 10% × 5 hours] + [(1,499 large broker-dealers + (…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ns described in Section III(a)-(f) for each plan and IRA. In total, the Department estimates that 2,996 entities would prepare disclosures for plans and 2,996 entities would prepare disclosures for IRAs. The Department assumes that an in-house attorney will spend one hour of legal staff time drafting the disclosure for…
IRCCourt RulingsFeb 28, 2024related by meaning
e was “intertwined with the merits,” i.e., with the
question of whether petitioner had actually made “excess contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability u…
IRCCourt RulingsDec 19, 1995★ strong match
…278, 288 n.6 (1973); Stengel v. Commissioner
, T.C. Memo.
1992-570, affd. without published opinion 996 F.2d 1227 (9th Cir. 1993);
Cotter v. Commissioner
, T.C. Memo. 1991-316.
4
For a discussion of the Retirement System and the Pension System, see
generally Hylton v. Commissioner
, T.C. Memo. 1995-27; Hoppe v. Commiss…
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…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ificantly reduces the risk retained by the plan sponsor.[205]
Applying this percentage to the 2,454,996 small, ERISA-covered group health plans,[206]
the Department estimates there are approximately 1,031,098 level-funded group health plans.[207]
The Department also estimates that there are 104,123 self-insured group h…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…stimated baseline monthly storage cost of roughly $22,583 with an annual cost of approximately $270,996. With a 70 percent reduction in file size, monthly storage costs would decrease to approximately $6,651 ($79,812 annually), yielding a monthly savings of $15,932 and an estimated annual savings of approximately $191,…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
IRCCourt RulingsAug 8, 1996related by meaning
…ew the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jurisdiction to abate
- 8 -
interest herein. See Commissioner v. McCoy
, 484 U.S. 3, 7
(1987); 508 Clinton Street Corp. v. Comm…
IRCCourt RulingsJun 17, 1997
…in the Prime Plan
listed the following relevant data:
1988
1989
1990
1991
Fund value at yearend $99,996 $138,653 $158,161 $167,047
Policy values 99,996 138,653 157,814 167,055
Surrender value Unstated Unstated 136,959 147,056
Addit. contr. available (11) 2 61,519 128,443
Date of report 03/11/91 03/11/91 07/10/91 01/20/…
IRCCourt RulingsAug 12, 1998related by meaning
…rt of the State of Arizona,
in and for the County of Pima, in a final judgment dated
September 30, 1996, relating to a complaint filed on October 18,
1993, by Walter McBee and Triple L Distributing Co., against
Estes Homes and other entities, found that petitioner's
partnership interest in Estes Homes was terminated be…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…cost
Total estimated
cost
2021
17,467
17,467
59,472
$6,758,568
$2,965
$6,761,533
2022
17,467
50,797,996
0
0
2,539,900
2,539,900
2023
17,467
50,797,996
0
0
2,539,900
2,539,900
3 Year Average
17,467
33,871,153
19,824
2,252,856
1,694,255
3,947,111
IRCCourt RulingsMar 1, 1999related by meaning
me-generating activities
relating to the items of income, he has satisfied that obligation
through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation
should have been divided between himself and his spouse, there is
no basis for making any apportionment. …
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…ses would have been $567,884 for BI's fiscal year 1988,
- 29 -
$888,742 for BI's fiscal year 1989, $996,886.40 for BI's fiscal
year 1990, and $287,010 for BI's fiscal year 1991. This
computation is as follows:
Income before 8-percent of 8-percent of
taxes of GSI income before income before
FY ended
& subsidiaries
taxes…
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
.
89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption PBGCFinal Rules (FR)Dec 20, 2024
…8468
0.48417
112
0.49268
0.49226 113
0.49666
0.49634
114
0.49795
0.49773
115
0.49928
0.49915
116
0.49960
0.49953
117
0.49978
0.49973
118
0.49995
0.49993
119
0.50000
0.50000
120
1.00000
1.00000
( printed page 104043)
3. Amend § 4044.58 by revising table 1 to § 4044.58 to read as follows:
§ 4044.58
Tables used to determi…
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 RulingsJun 10, 1957related by meaning
OPINION.