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91 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003★ strong match
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  2. Treas. Reg. § 54.9802-1(c)(2)(iii) — Prohibiting discrimination against participants and beneficiaries based on a health factor.
    IRCRegulationsDec 30, 2016
    …se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
  3. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011★ strong match
    … there is no genuine issue of materïal fact and a decision may be rendered as a matter of law. Rule 121(a) and (b); Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). The moving party bears the burden of proving that there is.no genuine issue of material fact, and factual inferences are.viewed in a light most f…
  4. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008★ strong match
    are petitioner's and respondent's cross-motions for summary ·judgment pursuant to Rule 121. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the years in 1ssue. Rule 121(a) provides that either…
  5. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990★ strong match
    hould prevail on the substantive issues as a matter of law. Rule 121(b); Naftel v. Commissioner, supra at 529; Espinoza v. Commissioner, supra at 416. Rule 121(d) provides that “an adverse party may not rest upon the mere allegations or denials of such party’s pleading, but such party’s response, by affidavits or as ot…
  6. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005★ strong match
    … judgment motion, and the sole argument presented in the response to the second motion is that Rule 121 does not provide for - 8 - repeated motions for summary judgment. This argument is without merit. Rule 121 does not prevent successive motions for summary judgment. We conclude that petitioners are liable for the 10-…
  7. 78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
    IRCFinal Rules (FR)Jun 3, 2013
    ….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010). 8. In § 146.121, paragraph (f) is revised t…
  8. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
  9. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017★ strong match
    …t he did not receive these items of income or that the income he received was not taxable. See Rule 121(d). We conclude that respondent's determinations of unreported income as set forth in the notice of deficiency are correct, and those determinations are sustained. See Hardy v. Commissioner, 181 F.3d 1002, 1004 (9th …
  10. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  11. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * 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 w…
  12. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  13. 98 T.C. 283; 98 T.C. No. 23 — Aronson v. Commissioner
    IRCCourt RulingsMar 18, 1992related by meaning
    s have failed in their burden of proof. Rule 142(a). To reflect the foregoing and concessions by the parties, Decision will be entered under Rule 155. All section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. Petiti…
  14. 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…
  15. 77 FR 70620 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
    IRCProposed Rules (FR)Proposed Nov 26, 2012
    ….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010). 2. In § 146.121, paragraph (f) is revised t…
  16. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  17. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  18. T.C. Summary Opinion 2017-88 — J. Drew Koester v. Commissioner
    IRCCourt RulingsDec 4, 2017
    …onal alimony" is a class of alimony that a Tennessee court may award. See Tenn. Code Ann. sec. 36-5-121(d)(1) through (g)(1). It terminates on the death of he recipient. Id. sec. 36-5-121(g)(3). It is described as a sum of money payable by a spouse for a determinate period and awarded "when the court finds that rehabil…
  19. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021
    …ay move for summary judgment regarding all or any part of the legal issues in controversy. See Rule 121(a); Wachter v. Commissioner, 142 T.C. 140, 145 (2014). We may grant summary judgment if the pleadings, stipul ations and exhibits, and any other acceptable materials show that there is no genuine dispute as to any ma…
  20. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…