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 RulingsDec 18, 2012★ strong match
…0FFB1604 -0- -0- 415,339 769,501 519,925 -0FFB2520 -0- -0- -0- 139,412 84,500 -0FFB2740 483,616 157,654 -0- -0- -0- -0FSB5068 -0- -0- -0- -0- 424,084 815,963
NWB8531 -0- -0- -0- -0- 33,483 -0Total 550,601 589,687 723,822 1,151,061 1,150,989 827,556
Respondent determined in Ms. Zaklama's notice of deficiency that she re…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsSep 29, 2016
… bills.
On her joint tax return for the 2012 tax year, petitioner reported retirement
income of $19,654 that she received from the Teacher Retirement System of
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Texas. Petitioner did not report the retirement income of $39,650 that she had
withdrawn from her Citibank retirement account. Petitioner also claimed a s…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
ERISACourt RulingsAug 10, 2026
…public meaning of its terms at the time of its
enactment.” Bostock v. Clayton Cnty ., 590 U.S. 644, 654 (2020).
One way to do that is by examining “ dictionaries published close in time to when
[the statute] was enacted . ” Davidson v. United Auto Credit Corp. , 65 F.4th 124, 129 (4th
Cir. 2023). We b egin with the wor…
ERISACourt RulingsAug 10, 2026
…public meaning of its terms at the time of its
enactment.” Bostock v. Clayton Cnty ., 590 U.S. 644, 654 (2020).
One way to do that is by examining “ dictionaries published close in time to when
[the statute] was enacted . ” Davidson v. United Auto Credit Corp. , 65 F.4th 124, 129 (4th
Cir. 2023). We b egin with the wor…
IRCCourt RulingsNov 17, 2016
…mit 5% age 62 age 45 limit
2002 $160,000 0.4363 12.456 16.426 $52,936
2003 $160,000 0.4363 12.68 16.654 $53,150
2004 $165,000 0.4363 12.68 16.654 $54,811
2005 $170,000 0.4363 12.68 16.654 $56,472
2006 $175,000 0.4363 12.68 16.654 $58,133
Essentially, respondent applied a tripartite method to calculate the required
redu…
T.C. Memo. 2013-124 — Kenneth A. Carter, Robert J. Kurek, John McFawn, Paul L. Miles, Adolph F. Rivas, Curlee Thomas, and Q.C. Williams, Jr.; Petitioners v. Commissioner of Internal… IRCCourt RulingsMay 9, 2013
…ension Plan of A. Finkl & Sons Co., No. 08 C 7169, 2010
WL 1930133 (N.D. Ill. May 12, 2010), aff'd, 654 F.3d 719 (7th Cir. 2011).
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[*7] wrote to the Commissioner in opposition, arguing that Amendment 2 and
Finkl's subsequent refusal to pay petitioners their claimed in-service benefits
violated the anticutback prov…
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…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
or an adequate and full
consideration in money or money's worth.
Generally, transfers pursuant to agreements in settlement of disputes between adverse parties are not subject to the gift tax. See Beveridge
v. Commissioner, 1 0 T. C. 915
(1948); Estate
of Noland v. Commissioner, T.C. Memo. 1984-209; Lampert v.
Commissio…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …
IRCCourt RulingsFeb 22, 1989
…ccumulated contributions are to be credited to the Retiree’s Annuity Reserve pursuant to La.R.S. 42:654. The procedures established by La.R.S. 42:652, 653, and 654 are accounting functions; all employer contributions and employee contributions are commingled in the Title 42 Trust and are either invested or are used to …
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…-q3-2024-q4.pdf.
Back to Citation
213.
See Tex. Med. Ass'n
v.
U.S. Dep't of Health & Hum. Servs.,
654 F. Supp. 3d 575 (E.D. Tex. 2023),
aff'd,
No. 23-40217 (5th Cir. August 2, 2024) (
TMA II).
Back to Citation
214.
88 FR 75744, 75802 (November 3, 2023).
Back to Citation
215.
See Tex. Med. Ass'n
v.
U.S. Dep't of He…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…fers and Inactive Accounts.” (2014).
Back to Citation
99. The estimate is calculated as follows: 3,654,330 account consolidations × $42 = $153,481,860 in benefits. $153,481,860 × average of 4.5 years receiving benefit per account = $689,003,322 in total benefits. At a discount rate of 3 percent, this results in $552,0…
80 FR 71936 — Interpretive Bulletin Relating to State Savings Programs That Sponsor or Facilitate Plans Covered by the Employee Retirement Income Security Act of 1974 ERISAFinal Rules (FR)Nov 18, 2015
….”
New York State Conference of Blue Cross & Blue Shield Plans
v.
Travelers Ins. Co.,
514 U.S. 645, 654 (1995). The question turns on Congress's intent “to avoid a multiplicity of regulation in order to permit nationally uniform administration of employee benefit plans.”
Id.
at 654, 657.
See also Fort Halifax Packing C…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2010
…602
602
2,547
2,547
2016
614
614
2,598
2,598
2017
627
627
2,652
2,652
2018
640
640
2,708
2,708
2019
654
654
2,765
2,765
2020
668
668
2,823
2,823
2021 or later
682
682
2,882
2,882
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington, DC, this 29th day of November 2010.
Vincent K. Snowbarger,
Deput…
IRCCourt RulingsOct 10, 1979related by meaning
es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …