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Go to 27 T.C. 372 (not yet in the library — opens the official source)
78 documents · 0.50sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …. 2005-176. The Plan 15104 Form W-2 reflects a gross distribution to petitioner from Plan 15104 of $372,850 and that petitioner made no employee contributions to Plan 15104. The parties stipulated the accuracy of the Plan 15104 Form W-2, and no evidence in the record contradicts the Plan 15104 Fórm W-2. This evidence, …
  2. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    …le 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 with effective dates during 1980 and 1981; Act of October 10, 1980, Pub. L. 96-417…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    owing differences: I --between the amounts of royalties and other expenses referred to in article 74 of the mentioned Law, credited or paid during the base-year, and the minimum percentages established for the respective deduction, according to (b) and (d); II--between the quotas for the purpose of forming depreciation…
  4. T.C. Summary Opinion 2017-51 — Arthur Dulik, Jr. & Ellen B. Kugler Dulik v. Commissioner
    IRCCourt RulingsJul 13, 2017
    …e consequences that might result from a win or loss of a legal claim. See United States v. Gilmore, 372 U.S. 39 (1963); Kenton v. Commissioner, T.C. Memo. 2006-13, 2006 WL 237112; Test v. Commissioner, T.C. Memo. 2000-362, 2000 WL 1738858, aff'd, 49 F. App'x 96 (9th Cir. 2002). In Test v. Commissioner, 2000 WL 1738858,…
  5. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …per format. As Table 11 shows, the Department estimates the proposed rule, if finalized, will save $372 million in the first year and $395 million in subsequent years. 1. Rule Familiarization and Compliance Costs
  6. 34 T.C. 73 — Zeltzerman v. Commissioner
    IRCCourt RulingsApr 18, 1960★ strong match
    Section 403(a) of the Internal Revenue Code of 1954 is, in the main, a reenactment of section 22(b) (2) (B) of the Internal Revenue Code of 1939. The latter was enacted by section 162 of the Revenue Act of 1942, which also amended section 165 and section 23 (p) of the 1939 Code. The congressional committee reports deal…
  7. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …inancial Benefits Trust" (E.I.N. 86-6184818): 10 1990 1991 1992 1993 1994 Interest income $232,158 $372,992 $351,722 $106,927 $92,464 Other income: forfeitures --- 9,453 --- --- --- Other income: refund trustee fees --- --- --- --- 4,012 Tax exempt income 55,467 34,812 295,340 118,797 14,498 Total income 232,158 382,44…
  8. T.C. Memo. 2012-44 — James Anthony Fonteneaux, Sr. v. Commissioner
    IRCCourt RulingsFeb 21, 2012
    …NDUM FIND NGS OF FACT A OPINION COHEN, Judge: Respondent d±termined deficiericies of $15,635 and $2,372 in petitioner's Federal income taxes for 2005 and 2d06, respectively. < SE8vED FEB 2 1 2012 - 2 - Respondent also determined additions to tax under sections 6651(a)(1) for each year and a penalty under section 6662(a…
  9. 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’ …
  10. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    0-1/2 months of deductions in TYE 8801 for each of the 39 Multiemployer Plans to which it contributed. See Lucky Stores, Inc., & Subs. v. Commissioner , T.C. Memo. 1997-70. We are not convinced that Congress intended section 404(a)(6) to be read so expansively, or in a manner inconsistent with section 413(b)(7), - 38 -…
  11. T.C. Memo. 2018-155 — Ruben De Los Santos & Martha De Los Santos v. Commissioner
    IRCCourt RulingsSep 18, 2018
    … which it treated as tax-deductible expenses of the medical practice: Date Contribution 11/14/2006 $372,446 12/05/2007 372,446 10/08/2008 372,486 11/19/2009 372,485 10/27/2010 372,486 Total 1,862,349 During 2007-2012 the Legacy Trust (and later the Flex Trust) paid premiums on the Policy as follows: D_ate Premium paid …
  12. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  13. IRCCourt RulingsJun 13, 1977related by meaning
    f such sections, they shall be deductible under this section, subject, however, to the following limitations as to the amounts deductible in any year: (5) Other plans. — If the plan is not one included in paragraph (1), (2), or (3), in the taxable year in which an amount attributable to the contribution is includible i…
  14. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
  15. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  16. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999related by meaning
    penses which are ordinary and necessary and recurring in nature. Respondent relies on Rev. Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring expenses paid by an employer are not deductible under this regulation. We disagree. Our analysis starts at s…
  17. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    rom the proceeds of the life insurance contract. See generally Cadwell v. Commissioner, 136 T.C. 38, 63-64 (2011), aff'd, 483 Fed. Appx. 847 (4th Cir. 2012). Section 1.61-22, Income Tax Regs., is effective for split-dollar life insurance arrangements entered into after September 17, 2003, and an arrangement that is "ma…
  18. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    es for the whole of such period.” SEC. 1024. EFFECTIVE DATES. Section 1023 shall take effect on the date of the enactment of this Act. [Sept. 2, 1974] Petitioner also refers to the plan in St. Joseph Bank & Trust Co. v. Commissioner, T.C. Memo. 1975-182. Respondent made no argument that in any event the adoption of a p…
  19. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …s, and Optum Rx respectively reported $162.5 billion,[370] $185.4 billion,[371] and $133.2 billion [372] in revenue in 2024, according to the SEC 10-k filings. Even for “small” PBMs, the Department expects that annual receipts would not be significantly below the SBA threshold and that few PBMs have annual receipts lev…
  20. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).