IRCCourt RulingsJul 14, 2005★ strong match
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 …
IRCCourt RulingsJan 30, 2007
…rp IRA,
and the distributions from the Fidelity IRA and the US Bancorp
IRA to petitioners totaling $749,930. The par ies agree that the
rollovers from Plan 15105 and Plan 15106 to the Fidelity IRA and
the direct rollovers of $500,000 and $62,930 from Fidelity IRA to
the US Bancorp IRA are excluded from income. See sec.…
IRCCourt RulingsMar 26, 1979
…-edgement that, in general, policy loans are debts for purposes of the interest deduction. H. Rept. 749, 88th Cong., 1st Sess. 61-62 (1963), 1964-1 C.B. (Part 2) 125, 185-186; S. Rept. 830, 88th Cong., 2d Sess. 77-79 (1964), 1964-1 C.B. (Part 2) 505, 581-583.
To be sure, the policy loan herein falls within the literal …
IRCPrivate Letter RulingsOct 5, 2012
… U.S. 591 (1948),
Helvering v. Clifford, 309 U.S. 331 (1940), and Chri stoffersen v. United States, 749 F.2d 513 (8th Cir. 1984) (variable contract under which the
policyholder did not possess sufficient control over the separate account assets to be treated as owning them for tax purposes.) Rev. Rul. 2003-92,
IRCCourt RulingsAug 30, 2006related by meaning
rough prosecution
of a legal suit or action based upon tort or tort type rights, or
- 14 -
through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the
exclusion must derive from some sort of tort claim against the
payor. Rickel v. Commissioner
, 900 F.2d 655, 65…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
tions specialist. The labor rate is applied in the following calculation: 1,749,471 claims × 0.50 hours × $101.32 = $88,628,201.
Back to Citation
285. The burden is estimated as follows: 1,749,471 uninsured individuals in need of good faith estimates with additional items and services × 0.50 hours = 874,736 hours. A l…
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 RulingsMar 5, 2018related by meaning
om a related supplier, the FSC is treated no differently for tax purposes
from the way it would be treated if it were a C corporation. See, e.g., sec. 921(d).44 Consequently, contrary to the dissent's suggestion, and far from being a
44For example, if a related supplier had no export income in a particular
year, the FS…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…alculated as: 1 percent price reduction × 0.36 price elasticity × 600,768,000 prescriptions = 2,150,749 prescriptions.
Back to Citation
317.
This estimate is calculated as: $181.15 average prescription cost × 2,150,749 prescriptions = $389,618,503.
Back to Citation
318.
Sharon Faust,
Prepared Testimony Before the Uni…
38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner IRCCourt RulingsSep 21, 1962related by meaning
because in the opinion of the Canadian counsel, petitioner had no claim recognizable under Canadian law and to proceed with the suit would be costly. In July 1958 petitioner, through its counsel, engaged a French attorney to attempt to recover, through the liquidator of SNAB in France. Later in 1958 the French attorne…
IRCCourt RulingsApr 2, 2024
… have characterized the constraints of
the AIA as jurisdictional, see Bob Jones Univ. , 416 U.S. at 749. The AIA
has “almost literal effect,” thereby depriving courts of jurisdiction over
any suit for the purpose of restraining the assessment or collection of
any tax. Id. at 737, 749; see also Maze v. IRS , 862 F.3d 10…
IRCCourt RulingsFeb 6, 1996
… income tax return.
At sometime during 1989, petitioner received a distribution
in the amount of $6,749 from a profit-sharing retirement plan
(Plan) maintained by his former employer, Jacob Goldfinger
(Goldfinger). The Plan was a qualified plan under section
401(a). Petitioner left the employ of Goldfinger in August 19…
IRCCourt RulingsDec 2, 1981related by meaning
of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
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…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
…r August 1, 2016
after January 13, 2017.
§ 1903.15(d)(1)
$8,908
$9,054.
§ 1903.15(d)(1)
124,709
126,749.
§ 1903.15(d)(2)
124,709
126,749.
§ 1903.15(d)(3)
12,471
12,675.
§ 1903.15(d)(4)
12,471
12,675.
§ 1903.15(d)(5)
12,471
12,675.
§ 1903.15(d)(6)
12,471
12,675.
( printed page 5383)
Department of Labor
Employee Benefits…
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
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJul 18, 1968
…lvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963).
In view of these statutory changes, McNutt-Boyce Co., supra, is no longer applicable. The Commissioner’s determination is sustained.
Deci…
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…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…epare and Send Notice
[Automatic portability provider]
Year 1
Year 2
Year 3
Number of Notices
397,749
519,606
630,585
× Annual Hour Burden per Transaction (Hours)
2/60
2/60
2/60
= Total Hours
13,258
17,320
21,020
× Labor Cost (Clerical Professional)
$63.45
$63.45
$63.45
( printed page 5663)
= Equivalent Cost
$841,239…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
Atkins, Judge:
The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…