Search the Pension Law Library

1. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
   IRCCourt RulingsAug 27, 2026
   …o weeks , except for the month of December. In December 2018 she wrote him three checks totaling $1,812 : $900, $ 812 , and $ 100. Each check was made out to Mr. Janangelo personally . 9 Mr. Janangelo appeared on his own behalf and for Mrs. Janangelo as her attorney of record. We call Mr. Janangelo’s attention to Rule …
2. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
   IRCCourt RulingsMay 29, 1968
   …nt was, during the period of time relevant to the issue herein, the Soft Drink Workers Union, Local 812 (hereinafter referred to as local 812). Leo Greenfield, an attorney, represented local 812 in its negotiations with petitioner at all times relevant to the issue herein. Petitioner entered into its first collective-b…
3. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
   IRCCourt RulingsDec 18, 2012related by meaning
   hat the 10% additional tax under section 72(t) applies) to the extent stated; 6. whether petitioners may deduct itemized deductions in amounts greater than respondent allowed (which was zero for each year). We hold that they may not; and 7. whether petitioners are liable for the additions to tax under sections 6651(a) …
4. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
   IRCNoticesJun 8, 2026★ strong match
   …2 2026-6 2026-11 I.R.B. 2026-11 635 2026-7 2026-15 I.R.B. 2026-15 791 2026-8 2026-16 I.R.B. 2026-16 812 2026-9 2026-19 I.R.B. 2026-19 897 2026-10 2026-22 I.R.B. 2026-22 1515 2026-11 2026-24 I.R.B. 2026-24 1570 Treasury Decisions: Article Issue Link Page 10042 2026-03 I.R.B. 2026-03 320 10041 2026-04 I.R.B. 2026-04 360 …
5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996
   …r 1989, petitioners disclosed the receipt of the taxable portion of the Transfer Refund; i.e., $227,812. Of this amount, petitioners reported that $77,812 was taxable and that the balance, or $150,000, had been rolled over tax-free into an IRA. Petitioners attached Form 5329 "Return for Additional Taxes Attributable to…
6. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
   IRCCourt RulingsApr 16, 2020related by meaning
   to satisfy section 274(d). Accordingly, we sustain respondent's determination with respect to this issue. - 26 - [*26] 4. 2013 Schedule C2 Deductions The table below summarizes the expenses reported on petitioners' 2013 Schedule C2, the amounts disallowed in the deficiency notice, the amounts respondent concedes on br…
7. 90 FR 60432 — Transparency in Coverage
   IRCProposed Rules (FR)Proposed Dec 23, 2025
   …his figure is calculated by multiplying the annual cost per user after the file-size reduction ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600. Back to Citation 210.
8. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
   IRCCourt RulingsMay 19, 2011★ strong match
   b) (2) and 72. See Chevron U.S.A. Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842-843 (1984). II. Application of Sections 402(b) (2) and 72 Because we have found that section 402(b) (2) controls the tax consequences of the policy distributed to petitioners, -we now turn our attention to that section to deter…
9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJul 6, 2022★ strong match
   and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
10. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …a manner most favorable to the party opposing summary judgment.. Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344 (1982). The adverse party.must
11. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    an incident date. To determine whether Congress has spoken to this question, we consider the “plain” and “literal” language of the statute itself, the specific context in which the language is used, and the broader context of the statute as a whole. See Robinson v. Shell Oil Co. , 519 U.S. 337, 341 (1997); Allen v. Uni…
12. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
13. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
14. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
15. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …st rate and 5.82% for the second segment interest rate. (ii) A shortfall amortization base of −$379,812 is established for 2016, which is equal to the $2,500,000 funding target, reduced by the sum of $2,450,000 of assets, $316,696 (the present value of the remaining installments with respect to the 2015 shortfall amort…
16. 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…
17. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ce 2002-8 supra,-are unrêasonable or incorrect. Furthermore, on a motion f r summary judgm t thàt is prð];>erly'm de and supported, the o poeing party must 9et forth specific facts showing that there is a genuine issue fo trial. Rule 121(d) . Petitioner does not allege thathe has any evidence that wo ld sat-isfy 'that …
18. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
19. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
20. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …d section 6662A as part of the American Jobs Creation Act of 2004 (AJCA), Pub. L. No. 108-357, sec. 812(a), 118 Stat. at 1577. Section 6662A imposes a 20% accuracy-related penalty on reportable transaction understatements and is effective for taxable years ending after October 22, 2004. See sec. 6662A(a); seeialso AJCA…