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 …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…Preparation (In-House)
77,012 = 770,117 Plans × 10% Not Using a Service Provider
1
181.06
77,012
13,943,731
Adding Contact and Plan Information to Drafted Explanations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total
138,322
$18,646,718
Table 8—Cost for Distribution of New Paper …
IRCCourt RulingsNov 12, 1997
…5 taxable distribution from his law
firm's 401(k) plan; (3) whether petitioner is entitled to a $33,943
interest expense deduction; (4) whether petitioner is liable for an
addition to tax for failure to timely file his 1991 Federal income
t ax return pursuant to section 6651(a)(1); and (5) whethe r
petitioner is liable…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…n ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600.
Back to Citation
210. Annual storage savings of $57,355,200 is calculated by subtracting the total annual cost after file-size reduction ($23,943,600) from the total annual cost under current file-size assumpti…
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 RulingsJan 14, 2013
…297,798 13,949 311,747
20032 -0- 925,640 1,072 926,712
2004 -0- (917,045) -0- (917,045)
2005 -0- (3,943) -0- (3,943)
Total 16,356,316 519,577 362,091 881,668
1The Court has derived this column of information from the reported taxable
income and depreciation amounts on the Forms 1120.
2The facility was sold in 2002, and…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
ERISACourt RulingsAug 14, 2026
…t promised lifetime benefits will indeed survive
for a lifetime.” Stone v. Signode Indus. Grp. LLC , 943 F.3d 381,
385 (7th Cir. 2019) (emphasis in original) ; s ee Tackett, 574 U.S.
at 442 (noting that “a collective-bargaining agreement [may]
provid[e] in explicit terms that certain benefits continue after
the agreement…
IRCCourt RulingsMar 9, 2011
…ted dividend income of $100,152, $99,916, and
$80,510 and paid Federal income taxes of $22,063,
$21,943, and $15,349,v respectively. TDH reported
dividend income of $100,152, $99,916, and $80,510 and
paid Federal income taxes of $22,063, $21,943, and
$15,349, respective.ly. TLS reported dividend income of
$100,152, $99…
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…
IRCCourt RulingsOct 21, 2003
…ified individual retirement accounts:
Nationwide Life Insurance Co. $5,000.00
First National Bank 3,943.33
Total distributions $8,943.33
Both institutions issued to petitioner Forms 1099-R,
IRCCourt RulingsMay 29, 1975
…b) was amended by section 1023 of the Employee Retirement Income Security Act of 1974.88 Stat. 829, 943. It now provides: (b) Certain Retroactive Changes in Plan. — A stock bonus, pension, profit-sharing, or annuity plan shall be considered as satisfying the requirements of subsection (a) for the period beginning with …
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsMay 14, 2001related by meaning
December 19, 1989,
- 6 -
for tax years ending after the date of enactment. See OBRA sec.
7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section
414(p)(11) and cannot qualify as a QDRO.
The decree provided that petitioner is to receive a "sum of
money equa…
IRCCourt RulingsApr 2, 2020
…ue Code that "limit or prohibit interest under certain conditions". IA sec.
2.01(2), 1960-2 C.B. at 943. These provisions create a type of interest called
"restricted interest". R Some of the Code provisions that can give rise to
restricted interest include sec. 172(b) (2002) (NOL carrybacks), amended by Tax
Cuts and J…
IRCCourt RulingsOct 25, 1999related by meaning
spondent's determination
that she is liable for a 10-percent additional tax on her 1995
IRA distribution. Since petitioner fails to qualify for any of the statutory exceptions under section 72(t)(2), we hold that
petitioner is liable for the 10-percent additional tax on
distributions from a qualified retirement plan fo…