IRCCourt RulingsMay 3, 1995
…ng amounts:
Deductions Contributions
Year Claimed Cumulative Paid Cumulative Difference
1983 $1,725,684 $1,725,684 -0- -0- $1,725,684
1984 1,451,184 3,176,868 $768,305 $768,305 2,408,563
1985 1,007,903 4,184,771 879,700 1,648,005 2,536,766
Deductions Contributions
Year Claimed Cumulative Paid Cumulative Difference
-0-4…
IRCCourt RulingsJan 14, 2013★ strong match
…7,264 12,923 (5,659)
1984 29,955 6,000 ! 23,955 6,968 -0- 6,968
-26-
[*26]
1983 28,899 -0- 28,899 6,684 -0- 6,684
1982 27,881 -0- 27,881 6,412 -0- 6,412
1981 26,899 -0- 26,899 6,151 -0- 6,151
1980 25,952 -0- 25,952 5,900 -0- 5,900
1979 25,037 -0- 25,037 5,660 -0- 5,660
1978 24,155 -0- 24,155 5,429 -0- 5,429
1977 23,304…
79 FR 13949 — Amendment Relating to Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAProposed Rules (FR)Proposed Mar 12, 2014
…that there are 2.2 million covered arrangements between 12,000 covered service providers and nearly 684,000 covered plans for which disclosures are required under the final rule. While some of these arrangements are simple, others are complex and would require much information to be disclosed. The Department is not awa…
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 RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …
IRCCourt RulingsAug 4, 2005
…isting of tuition, fees, and room and board. Petitioners
argue that additional expenses totaling $2,684.30 are also
qualified higher education expenses and should not be subject to
the 10-percent additional tax. The disputed $2,684.30 is made up
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 RulingsDec 29, 2008
…0, except
for 1996 where they had a refund due . The total amount due, including additions, was $48,684 . On behalf of the Martinezes
the law firm prepared an offer-in-compromise, offering $1,000 to
settle the entire debt . The firm submitted the offer to the IRS
during the summer of 2001 after Mr . Martinez's death in…
IRCCourt RulingsDec 23, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCCourt RulingsMar 5, 2018★ strong match
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
IRCFinal Rules (FR)Nov 12, 2020
…sponses
Burden hours
per respondent
Total burden
hours
Total cost
1,959
23,508
372
728,748
$106,326,684.00 The Departments estimate the total one-time year one burden for all issuers and TPAs will be 15,178,332 hours, with an associated equivalent cost of approximately $2,024,117,160 to develop and build the In-network…
IRCCourt RulingsJul 31, 2000
…d, at the end of that
year, the conversion credit balance was $15,903.15 ($19,004.55 -
$3,786.22 + $684.82); the $684.82 is the interest of 4.5 percent
earned on the conversion credit balance (($15,903.15 - $684.82) x
4.5% = $684.82)). None of the conversion credit balance could
have been transferred at this time to th…
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 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 11, 1957
…h was given to her by Clarence. On the day she opened the account she drew three checks totaling $1,684.30 to pay the initial premiums on the Prudential, Home Life, and John Hancock policies. Subsequent premium payments to the insurance companies with respect to the above policies were made by checks drawn upon this ac…
IRCCourt RulingsJul 24, 1996
… for decision is
whether and to what extent, if any, Parker-Hannifin Corporation
may deduct $32,498,684 in contributions it made to a welfare
benefit trust on June 30, 1987.
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
ERISACourt RulingsJun 26, 2013
…of Labor Office of Administrative Law Judges
36 E. 7th St., Suite 2525
Cincinnati, Ohio 45202
(513) 684-3252
(51 3) 684-6108 (FAX)
Issue Date: 26 June 2013
Case Nos.: 2010 - RIS - 00013
2012 - RIS - 00113
2012 - RIS - 00114
In the Matter of:
UNITED STATES DEPARTMENT OF LABOR,
EMPLOYEE BENEFITS SECURITY
ADMINISTRATION,
…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…