120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
10,592,106 132,541,874
C. Value of assets (beginning of year)
a. VEBA --- 30,736,554 30,176,217 39,940,676
b. 401(h) --- 1,125,467
1,172,269
7,598,653 c. Total --- 31,862,021 31,348,486 47,539,329
D. Nondeductible contribution from prior
years (O from prior year) --- 22,034,781 14,394,743 14,426,384
E. Net value of ass…
IRCCourt RulingsJan 14, 2013★ strong match
ALS
T.C. Memo. 2013-10
UNITED STATES TAX COURT
THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners
V.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013.
1481-10.
R determined that a corporation's compensation packages for its
owner-employees were unreasonabl…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsAug 30, 2006related by meaning
only to the extent authorized by
Congress. Sec. 7442; Trost v. Commissioner
, 95 T.C. 560, 565
(1990). Our jurisdiction to redetermine a deficiency is dependent on the issuance of a valid notice of deficiency and the
timely filing of a petition. Secs. 6212, 6213; Rule 13(a), (c).
To be timely, a petition must generally…
IRCCourt RulingsSep 25, 1996related by meaning
................................. 9
MIT 80.................................................. 12
Formation of MIT 80................................ 12 Investors in MIT 80................................ 13
Organization and Management of MIT 80.............. 13
MIT 80 Employee Leasing Arrangement................ 14
Oper…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… transfer ($18,795) by the total annual downloads (1,200): $18,795 × 1,200 downloads per year = $22,554,000.
Back to Citation
218.
Total network cost savings are calculated by subtracting the total annual network costs for the new files downloaded quarterly ($22,554,000) from the total annual costs for the current mon…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
…rs the following amounts for
renewal premiums:
Date
Premiums
9/6/83 $549,699
7/23/84 556,843
9/6/85 554,390
8/26/86 554,390
8/28/87 530,650
8/31/88 526,325
6. Commissions Paid by Travelers to the Garrahan Agency
During the years at issue, the Garrahan Agency received the
following amounts as commissions from Travelers …
85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 7, 2020
…
2028
786
786
3,319
3,319
2029
804
804
3,396
3,396
2030
822
822
3,474
3,474
2031 or later
841
841
3,554
3,554
1
Applicable tables for valuation dates before 2021 are available on PBGC's website (
www.pbgc.gov).
2
Table II-A.
3
Table II-B.
4
Table II-C.
* * * * *
Issued in Washington, DC.
Hilary Duke,
Assistant Gene…
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 RulingsOct 10, 1979
…erest element in mind. See, e.g., H. Rept. 704, 73d Cong., 2d Sess. 21 (1934), 1939-1 C.B. (Part 2) 554; S. Rept. 558, 73d Cong., 2d Sess. 23 (1934), 1939-1 C.B. (Part 2) 586. Admittedly, an interest factor is usually present where an annuity is involved. See Hill’s Estate v. Maloney, 58 F. Supp. 164 (D. N.J. 1944); La…
IRCRegulationsSep 9, 2016
…. Accordingly, the waiver amortization installments with respect to the 2016 funding waiver are $40,554 each, payable beginning January 1, 2017. Example 4.(i) The facts are the same as in Example 3. As of January 1, 2017, Plan A has a funding target of $2,750,000 and assets totaling $1,900,000. For purposes of this exa…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…ost
(A)
(B)
(C)
(D)
(A × [(B × C) + D])
Duplicate Statements for DB Plan Participants 1,176 = 301,554 DB Participants in small plans under the 2020 safe harbor × 3.9% Receiving Paper Statements Pre-Statute × 10% Receiving Duplicate Statements per Year
$1.00
$0.05
$1.00
$1,235
Duplicate Statements for DC Plan Particip…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCPrivate Letter RulingsOct 5, 2012
…ty of title, determine tax
ownership. For example, in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed.
15
It is intended that these investments will at least equal the SIV of all contracts at any point in t ime but they will not match the HAB. Moreover, only
the SMV and SIV, as applicable, determine Taxpayer…
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 RulingsJan 19, 2001
…as follows:
Accuracy-Related Penalty
Year
Deficiency
Sec. 6662(a)
1993 $11,805 $1,915
1994 13,511 1,554
1995 14,307 1,597
- 2 -
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
…