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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   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 …
2. 89 FR 85099 — Energy Efficient Home Improvement Credit
   IRCProposed Rules (FR)Proposed Oct 25, 2024
   …tion is also consistent with prior guidance provided by the IRS. See Notice 2013-70, 2013-47 I.R.B. 528 (“A taxpayer can claim the § 25C credit only for qualifying expenditures incurred for an existing home or for an addition or renovation to an existing home, and not for a newly constructed home”); Notice 2009-53, 200…
3. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
   IRCCourt RulingsSep 25, 1996
   …however, remove the previous partnership names for several years, “just to be sure”. MIT 83 paid $2,528,416 to employees and independent contractors and taxing authorities. It paid out additional professional and bank fees, pension expenses and workmen's compensation, health, and group life insurance premiums. In addit…
4. Treas. Reg. § 1.72-5(a)(3) — Expected return.
   IRCRegulationsJul 26, 2016
   …purchased the same contract after June 30, 1986, the expected return under the contract would be $3,528, computed as follows: Monthly payments of $60 × 12 months equals annual payment of $720.00 Multiple shown in Table VIII for annuitant, age 60, for term of 5 years 4.9 Expected return for 5-year temporary life annuity…
5. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
   IRCCourt RulingsJun 24, 2003★ strong match
   tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
6. 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…
7. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
   IRCRegulationsSep 9, 2016
   …0 ÷ 1.055 0.5) as of December 31, 2010, and the balance of the minimum required contribution is $25,528 ($45,000 − $19,472). This balance will be covered by the plan sponsor's election to use the prefunding balance to offset any portion of the minimum required contribution not covered by cash contributions.(iii) Under …
8. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
   IRCTreasury DecisionsSep 18, 2006related by meaning
   INCOME TAX Notice 2006-76 Notice 2006-76 This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
9. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
   IRCCourt RulingsDec 24, 1985★ strong match
   …aws of the Nation.” United States v. Cartwright, 411 U.S. 546, 550, 93 S.Ct. 1713, 1716, 36 L.Ed.2d 528 (1973); accord, United States v. Correll, 389 U.S. 299, 307, 88 S.Ct. 445, 450, 19 L.Ed.2d 537 (1967); see 26 U.S.C. sec. 7805(a). We therefore must defer to Treasury Regulations that "implement the congressional man…
10. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
12. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
13. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020
    …suspect classification for purposes of the equal protection analysis. Kimel v. Fla. Bd. of Regents, 528 U.S. 62, 83 (2000) ("[A]ge is not a suspect classification under the Equal Protection Clause.") (citing Gregory v. Ashcroft, 501 U.S. 452, 470 (1991), Vance v. Bradley, 440 U.S. 93, 97 (1979), and Mass. Bd. of Ret. v…
14. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … negotiations, could result in estimated cost savings of approximately $69.4 million across the 383,528 impacted level-funded and self-insured group health plans that are expected to initiate new contracts, extend existing contracts, or renew contracts each year.[260]
15. T.C. Memo. 2020-25 — Alvin E. Keels, Sr. v. Commissioner
    IRCCourt RulingsFeb 19, 2020
    …x Penalty Year Deficiency sec. 6651(a)(1) sec. 6662(a) 2012 $117,659 $29,415 $23,532 2013 62,642 12,528 12,528 2014 98,732 4,932 19,746 After concessions,2 the issues for decision are: 1. Whether petitioner has substantiated any deductions in amounts greater than respondent allowed. We hold that he has to the extent di…
16. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
17. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    IRCCourt RulingsSep 24, 2026
    …oss i ncome of $ 174,432 (consisting chiefly of wages of petitioner’s wife), a tax liability of $20,528 , and an overpayment of $4,799. They did not report any retirement distributions. The IRS selected this return for examination and , on August 2, 2024, issued petitioner and his spouse a timely Notice of Deficiency .…
18. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
19. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …f Corporate Finance (February 2020). Back to Citation 776.  The burden is estimated as follows: (19,528 Financial Institutions × 10 requests) × (30 minutes ÷ 60 minutes) = 96,450 hours. A labor rate of $165.71 is used for a legal professional. The labor rate is applied in the following calculation: [(19,528 Financial I…
20. 85 FR 40834 — Improving Investment Advice for Workers & Retirees
    ERISAProposed Rules (FR)Proposed Jul 7, 2020
    …f the proposed exemption on small entities. In December 2018, there were 985 small-business BDs and 528 SEC-registered, small-business IAs.[175] The Department estimates that approximately 52 percent of these small-businesses will be affected by the proposed exemption.[176] In December 2018, the Department estimates th…