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69 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. DOL Office of Administrative Law Judges — USDOL, EMPLOYEE BENEFITS SECURITY ADMINISTRATION v. PLAN ADMINISTRATOR, WHITE MOUNTAIN APACHE TRIBE RETIREMENT SAVINGS AND 401(K) PROFIT SHARING PLAN ANNUAL RE…
    ERISACourt RulingsNov 30, 2016
    …nclude cer tain Indian Tribal government plans. Pub. L. No. 109-208, § 806(a)(2)(A), 120 Stat. 780, 1051 (Aug. 17, 2006). To be eligible for treatment as a governmental plan and exempt from ERISA reporting
  3. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    petitioner sought to deduct, as the sole shareholder, the entire net operating loss of $16,946.11 for the initial short taxable year on his Form 1040. We held in Bianchi that the contribution, including the compensation paid to petitioner during the initial 7-day taxable year, was unreasonable and properly disallowed, …
  4. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    tions in his gross income for 1995. The only exception to section 408(d)(1) that might apply in the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The transfer of an individual's interest in an individual retirement account or an individual retirement annuity to his spo…
  5. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …e "substantially vested." Sec. 1.83-1(a)(1), Income Tax Regs.; see Strom v. United States, 641 F.3d 1051, 1056 (9th Cir. 2011). Section 83(c) provides that "[t]he rights of a person in property are subject
  6. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  7. 35 T.C. 405 — Coppola v. Commissioner
    IRCCourt RulingsDec 9, 1960
    …re not includible in the gross income of petitioners for those years. Cf. Harold G. Perkins, 8 T.C. 1051, 1056. Decision will be entered under Bule 50. SEC. 402. TAXABILITY OF BENEFICIARY OF EMPLOYEES’ TRUST.
  8. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
  9. 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…
  10. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  11. 76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary
    IRCProposed Rules (FR)Proposed Aug 22, 2011
    …www.bls.gov/​oes/​current/​oes_​nat.htm#00-0000 ) for computer systems analysts (Occupation Code 15-1051), insurance underwriters (Occupation Code 13-2053), financial managers (Occupation Code 23-1011), executive secretaries and administrative assistants (Occupation Code 43-6011), and attorneys (Occupation Code 23-1011…
  12. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    IRCCourt RulingsMay 28, 1996
    …select group of management or highly compensated employees”; i.e., a “top hat” plan. 29 U.S.C. sec. 1051(2) (1994); see also Modzelewski v. Resolution Trust Corp. , 14 F.3d 1374, 1377 n.3 (9th Cir. 1994) (referring to the characteristics of a “top hat” plan). However, the plan under consideration is overfunded and cove…
  13. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    T.C. Memo. 2011-104 UNITED STATES TAX COURT PATRICIA LOUISE HYDE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8225-10. Filed May 19, 2011. Patricia Louise Hyde, pro se. Dessa J. Baker-Inman, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Respondent determined a $33,498 de…
  14. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty. OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
  15. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …the taxpayer had a non-tax business purpose for the transaction)." Reddam v. Commissioner, 755 F.3d 1051, 1057 (9th Cir. 2014), T.C. Memo. 2012-106; see also Bank of N.Y. Mellon Corp. v. Commissioner, 801 F.3d 104, 115 (2d Cir. 2015), 140 T.C. 15 (2013) and
  16. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    r personal injuries or sickness to the extent such amounts are (A) attributable to - 11 - 7 Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining age 65 by completely disabled persons retired on disability. Sec. 105(d) was repealed by sec. 122(b) of t…
  17. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    …Pediatrics 104:5 (1999), available at: http://pediatrics.aappublications.org/​cgi/​reprint/​104/​5/​1051. Back to Citation 35.
  18. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016
    …ting mitigation, has the burden of showing its applicability. See Bradford v. Commissioner, 34 T.C. 1051, 1054 (1960); see also United States v. Rushlight, 291 F.2d 508, 514 (9th Cir. 1961) (addressing predecessor section 3801 of the 1939 Internal Revenue Code). Respondent argues that because JVC Trust did not have to …
  19. 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…
  20. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    y [section 403(a) of ERTA], then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent. [1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…