IRCCourt RulingsFeb 9, 2023
… the economic activities
each undertakes. See H.R. Rep. 99-281, 99th Cong., 2d
Sess. (1986) at II - 637.
Id. The citation of “H.R. Rep. 99-281, 99th Cong., 2d Sess. (1986) at II -
637” was apparently an error. The cited report, H.R. Rept. No. 99-281,
appears to be unrelated to tax law.
146
The House report that was rel…
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 RulingsDec 29, 2005related by meaning
ic employees, (2) the
plan would pay her a taxable annuity after she reaches age 60,
(3) the plan has no survivor benefits, and (4) she would lose all benefits under the plan if she stopped contributing to it.
. The record includes a summary of a tax convention signed by
representatives of France and the United States …
IRCRegulationsSep 9, 2016
…der paragraph (d)(3)(i) of this section. Accordingly, the maximum single sum that P can receive is $637,200 (that is, the lesser of 50% of $1,416,000 or $637,200).(iv) Pursuant to paragraph (d)(3)(ii) of this section, Plan A must offer P the option to bifurcate the benefit into unrestricted and restricted portions. The…
IRCProposed Rules (FR)Proposed Oct 15, 2007
…e present value of the PBGC guaranteed benefit using actuarial assumptions under section 417(e) is $637,200. (iv) Because Participant P retires during a period when the restriction in paragraph (d)(3) of this section applies to Plan A, only a portion of the benefit can be paid in the form of a single sum. P elects a si…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
acted section
7476 to establish a declaratory judgment procedure under which an
- 6 -
employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept.
93-807, supra
at 107, 1974-3 C.B. at 342. Section 7476 provides:
SEC. 7476. DECLARATORY JUDGMENTS
RELATING TO…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
ollection and Transparency Needed to Enhance DOT Oversight. GAO-17-637 (July 27, 2017).
Back to Citation
11.
49 U.S.C. 41713(b).
Back to Citation
12. A provider of air ambulance services is a covered “air carrier” if it has economic authority from the Department of Transportation to provide interstate air transportat…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
… are 301,312 + 120,525 = 421,837 and the total equivalent costs are $36,925,829 + $13,712,123 = $50,637,952. The printing and material costs are $12,052. Therefore, $50,637,952 + $12,052 = $50,650,005.
Back to Citation
280.
301,312 + 120,525 = 421,837 and the total equivalent costs are $36,925,829 + $13,712,123 = $50,…
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 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
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 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…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
… the written description. This results in an hour burden of 4,000 hours with an equivalent cost of $637,360 in the first year.[58]
Table 8—Hour Burden and Equivalent Cost Associated With the Written Statement of the Independent Producer's Material Conflicts of Interest
Activity
Year 1
Subsequent years
Burden hours
Equi…
IRCCourt RulingsDec 11, 1997related by meaning
o be
treated as an amount received as a loan on the date of such
renegotiation, extension, renewal, or revision. TEFRA, sec.
236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2)
if it (1) is in an amount not exceeding a prescribed ceiling that
in no event may be more than $50,000, …
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review 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 jur…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsSep 25, 1996
…86.
MIT 82 accordingly reported partnership taxable income of
$840,069 for 1987. This consisted of $637,316, one-fourth of the
- 45 -
$2,549,264 deferred income that it was allocating over 4 years,
plus $231,253 in accrued interest payable from MPC, less
$28,500--a management fee expense to BBPA.
On its partnership ret…