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1. 76 T.C. 861; 2 Employee Benefits Cas. (BNA) 1450 — Estate of Perl v. Commissioner
   IRCCourt RulingsMay 27, 1981
   OPINION Tannenwald, Judge: Respondent determined a deficiency of $20,077.06 in petitioner’s Federal estate taxes. Concessions having been made by petitioner, the issue remaining is whether the proceeds of an insurance policy purchased by the decedent’s employer as part of an employee benefits program are includa-ble in…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
3. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
   IRCCourt RulingsJun 14, 2012related by meaning
   ed work in her capacity as Yolo's employee or officer. Consistent with our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the …
4. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
   IRCCourt RulingsJan 9, 1985related by meaning
   section 4975 as follows: (c) Effective Date and Savings Provisions.— (1)(A) The amendments made by this section shall take effect on January 1, 1975. (B) If, before the amendments made by this section take effect, an organization described in section 401(a) of the internal Revenue Code of 1954 is denied exemption unde…
5. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
   IRCCourt RulingsJan 29, 2019related by meaning
   ir market value need not be stated). Sec. 1.170A-13(b)(1), Income Tax Regs. For any contributions of $250 or more,8 the taxpayer must substantiate the contribution with a "contemporaneous written acknowledgment" from the charitable organization. Sec. 170(f)(8)(A). The written acknowledgment must include: (1) the amount…
6. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   argument that the statute of limitations should be treated as a substantive limit on their case rather than as a procedural limit on the reme dy) . 40 The Supreme Court observed in Landgraf that “the great majority of [its] decisions relying upon the antiretroactivity presumption have involved intervening statutes burd…
7. Treas. Reg. § 1.403(b)-2(b)(20) — Definitions.
   IRCRegulationsMay 18, 2016
   … tribal government is treated as a State, as provided under section 7871(a)(6)(B). See also section 1450(b) of the Small Business Job Protection Act of 1996 (110 Stat. 1755, 1814) for special rules treating certain contracts purchased in a plan year beginning before January 1, 1995, that include contributions by an Ind…
8. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
   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…
9. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
   IRCCourt RulingsJun 17, 1997
   …: New plan installation: $250 Annual service costs First 5 participants: 1050 6 to 10 participants: 1450 11 & over: 1650 + $20 per participant Trustee's transaction fees: 15 per transaction Individual benefit certification: Vested participants: 50 Non-vested participants: 35 Plan amendments: 250 Plan terminations: 650 …
10. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
11. 124 T.C. No. 10 — John Michael Dunkin v. Commissioner
    IRCCourt RulingsMar 31, 2005
    …case; i.e., petitioner paid his former spouse the benefit - 16 - 14 Cf. Ablamis v. Roper , 937 F.2d 1450, 1459-1460 (9th Cir. 1991) (Employee Retirement Income Security Act of 1974, Pub. L. 93-406, sec. 1056(d), 88 Stat. 829, preempted a predeceasing nonemployee spouse’s right under California community property law to…
12. 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 …
13. 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…
14. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976
    …le the category compensation pension plan Construction and General Laborers Local Unions No. 689 or 1450
15. Notice 2005-71 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for October 2005 and the resulti…
    IRCNoticesOct 31, 2005related by meaning
    ntracting Party concerned will give as much notice of termination as feasible and such termination shall take effect as determined by legislative act. DONE at PRAIA, in duplicate, this 16th day of March, 2005, in the Portuguese and English languages, each text being equally authentic. In case of divergence between the …
16. 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…
17. Treas. Reg. § 1.411(d)-5 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
18. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
19. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
20. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…