IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCPrivate Letter RulingsOct 17, 2014
in Rev. Ruls. 73-599
and 77-92. Therefore, because Taxpayer does not have any right to a reversion of the existing
retiree life insurance reserve that will be transferred to a retiree health reserve within Trust, such
transfer
will not cause Taxpayer to realize income under section 61 with respect to the balance
attrib…
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…
IRCPrivate Letter RulingsOct 17, 2014
… a deduction under section 419
for the
taxable year or any prior taxable year.
In Revenue Ruling 73-599, 1973-2 C.B. 40, modified by Rev. Rul. 77-92, 1977-1 C.B. 41, the
issue was whether the
balance in a retired lives reserve had to be included in the gross income
of the
employer in the taxable year in which the emplo…
IRCPrivate Letter RulingsJun 13, 2014
…
section 419 for the taxable year or any prior taxable year.
PLR - 127298-13 6
In Revenue Ruling 73-599, 1973-2 C.B. 40, the issue was whether the balance in a
IRCCourt RulingsFeb 10, 1997related by meaning
e within the parameters
spelled out in section 404(a)(6), may be deducted in the prior
year, but only
if
they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's
Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
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 RulingsDec 19, 1995★ strong match
…ssue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1995-599
UNITED STATES TAX COURT
RHETT B. ROSS AND SANDRA L. ROSS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4985-93. Filed December 19, 1995.
Paula M. Junghans
, for petitioners.
Alan R. Peregoy…
91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information PBGCProposed Rules (FR)Proposed Jul 21, 2026
…ravating factors.
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
Subpart A—Purpose and Definitions
§ 4071.1
Purpose and scope.
IRCCourt RulingsJul 31, 2000
…an paid the first-year premium, and, at the end of
that year, the conversion credit balance was $14,599.19 ($17,390
- $3,419.48 + $628.67); the $628.67 is the interest of 4.5
percent earned on the conversion credit balance (($14,599.19 -
$628.67) x 4.5% = $628.67)). None of the conversion credit
- 37 -
balance could ha…
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…
86 FR 2541 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 13, 2021
… read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,233” are removed and the figures “$2,259” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER…
IRCCourt RulingsAug 22, 1994
…unt that could be accumulated under the principles of Rev. Ruis. 69-382, 1969[ — 2] C.B. 28, and 73-599, 1973-2 C.B. 40. * * * [H. Conf. Rept. 98-861 (1984), 1984-3 C.B. (Vol. 2) 1, 417.]
This quote from the legislative history is relevant for two reasons. First, the conferees again spoke of a “reserve” in terms of an …
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…
77 FR 71321 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 30, 2012
…um 2
if monthly
benefit at URA is—
High 3
if monthly benefit at URA is greater than—
From—
To—
2014
599
599
2,531
2,531
2015
611
611
2,582
2,582
2016
623
623
2,633
2,633
2017
636
636
2,688
2,688
2018
649
649
2,745
2,745
2019
663
663
2,803
2,803
2020
677
677
2,861
2,861
2021
691
691
2,922
2,922
2022
706
706
2,983
2,983
…
IRCFinal Rules (FR)Aug 17, 2011
…$0.027. Decreasing the number of paper forms by 6.5 million will save the agency approximately $175,599 per year.
3. Labor
CBP estimates the cost of contractors employed to print the paper courtesy notices is $0.08 per copy. Based on this estimate, the cost savings on labor for printing is approximately $520,294 per ye…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…the unrounded amount per response of $44.225. 104,000 disputes withdrawn × $44.225 per dispute = $4,599,400 total cost.
Back to Citation
290.
This is calculated as follows: 0.25 hours per response × $41.94 hourly rate for an office clerk = approximately $10.49 per response.
Back to Citation
291.
This is calculated us…
85 FR 2304 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 15, 2020
… read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,194” are removed and the figures “$2,233” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER…
IRCCourt RulingsMar 5, 1987related by meaning
tions and are administered in a manner identical to the manner in which the payments to article III judges in regular active service are administered. Accordingly, petitioners are not here receiving the double tax benefit Congress sought to prevent by section 219(b)(2)(A).
Having decided that petitioners are entitled t…
90 FR 1374 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 8, 2025
… read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.34071.3
[Amended]
2. In § 4071.3, remove the number “$2,670” and add in its place the number “$2,739”.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MULTIEMPLOYER PLAN NOT…