IRCCourt RulingsFeb 9, 2023★ strong match
…computed without the stacking principle.
17
17
Petitioner contends that 3M Brazil’s net sales were $466,618,701 and that
therefore had 3M Brazil calculated the trademark royalties at 1% of sales without
stacking , 3M Brazil would have paid $4,666,187 in royalties. We do not find as fact
that 3M Brazil ’s net sales were…
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…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…Review:
Total
$350,946
$1,351,008
$1,406,278
$13,309
$4,661
$14,449
Per-Entity
$188
$170
$170
$189
$466
$466
Total:
Total
$5,178,174
$36,690,135
$38,191,149
$175,871
$503,542
$150,125
Per-Entity
$2,781
$4,624
$4,624
$2,492
$50,354
$4,843
SBA:
SBA Threshold
$47,000,000
$47,000,000
$47,000,000
$47,000,000
$47,000,000
$47…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsDec 18, 2012
…,428
1995 BOA3721 875
BOA3886 9,545
CB9250 1,500
FFB1604 5,988
17,908 1996 BOA3886 10,368
CB9250 10,466
FFB1604 8,916
NWB8531 12,060
41,810
1997 BOA3886 2,730
2,730
Respondent determined that the checks deposited in 1992 through 1994 represented
rental income to Ms. Zaklama and that the checks deposited in 1995 through…
IRCCourt RulingsMar 1, 1999related by meaning
me-generating activities
relating to the items of income, he has satisfied that obligation
through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation
should have been divided between himself and his spouse, there is
no basis for making any apportionment. …
IRCCourt RulingsAug 3, 1979★ strong match
to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption.
II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
IRCCourt RulingsSep 30, 1991related by meaning
tioners to believe that no taxable event was created by the above transactions for which any Federal excise tax returns would be required to be filed. On November 21, 1986, respondent issued a notice of deficiency to each petitioner, in the amounts set forth above, determining an excise tax pursuant to section 4975(a).…
IRCCourt RulingsJan 11, 2012
…
presentation, entitled "If You Keep Doin' What You're Doin'",
details how a taxable investment of $466,667 for each of 3 years
would perform over the next 15 years. The she t indicates that
at the end of 15 years the investment would have a balance of
$1, 683, 810 . The next sheet ris entitled "If You Implement The
Mi…
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…
79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary IRCProposed Rules (FR)Proposed Dec 30, 2014
…burden
SBC with Coverage Examples to Group Health Plan:
Renewal or Application
527,328 263,664
$105,466
$0
$105,466
Sub-total
527,328
263,664
105,466
0
105,466
SBC with Coverage Examples to Participants and Beneficiaries:
Upon Application or Eligibility
2,030,000
1,015,000
406,000
0
406,000
Upon Renewal
58,000,000
35,9…
ERISADOL Technical ReleasesMar 18, 2011
… Department of Managed Health Care Help Center
980 9th Street, Suite 500
Sacramento, CA 95814
(888) 466-2219
www.healthhelp.ca.gov
helpline@dmhc.ca.gov
ColoradoNo program
ConnecticutConnecticut Office of the Healthcare Advocate
P.O. Box 1543
Hartford, CT 06144
(866) 466-4446
www.ct.gov/oha
healthcare.advocate@ct.gov
De…
88 FR 83352 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 29, 2023
…less than—
Medium 3
if monthly benefit at URA is—
From—
To—
2025
802
802
3,388
3,388
2026
821
821
3,466
3,466
2027
839
839
3,546
3,546
2028
859
859
3,627
3,627
2029
879
879
3,711
3,711
2030
899
899
3,796
3,796
2031
919
919
3,883
3,883
2032
941
941
3,973
3,973
2033
962
962
4,064
4,064
2034 or later
984
984
4,157
4,157
1…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968★ strong match
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…
PBGCFinal Rules (FR)Jun 6, 2024
…High 4
if monthly
benefit at URA
is greater than—
From—
To—
2025
802
802
3,388
3,388
2026
821
821
3,466
3,466
2027
839
839
3,546
3,546
2028
859
859
3,627
3,627
2029
879
879
3,711
3,711
2030
899
899
3,796
3,796
2031
919
919
3,883
3,883
2032
941
941
3,973
3,973
2033
962
962
4,064
4,064
( printed page 48307)
2034 or later…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…, 721 (Cal.
2012) (quoting Charles A. Pratt Constr. Co. v. Cal . Coastal Com m’n , 76 Cal. Rptr. 3d
466, 471 ( Ct. App. 2008)). Regardless of whether the primary authority to issue c oastal
13
[* 13] The California Environmental Quality Act ’s final substantive
step is certification of the final EIR. Cal. Pub. Res. Cod…
IRCCourt RulingsJun 13, 2017
…-related penalty:2
Deficiency/ Penalty
Y_eg Overpayment sec. 6662(a)
2009 $429,444 $85,889
2010 (44,466) -0With respect to petitioners John Johnstun and Larue Johnstun, the IRS determined, for their 2009 and 2010 taxable years, the following Federal income tax
deficiency, overpayment, and accuracy-related penalty:
¹For…
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 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…