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85 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  3. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  5. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    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…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    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…
  7. 90 FR 60432 — Transparency in Coverage
    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…
  8. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    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…
  9. 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…
  10. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    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…
  11. 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 …
  12. 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…
  13. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    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…
  14. 73 T.C. 40 — La Fargue v. Commissioner
    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…
  15. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    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…
  16. 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…
  17. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    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 - […
  18. PLR 201240018 — Included vs. Not Included in Gross Income
    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…
  19. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    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…
  20. T.C. Memo. 2001-9 — WSB Liquidating Corporation v. Commissioner
    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. …