IRCCourt RulingsOct 25, 1999
T.C. Memo. 1999-352
UNITED STATES TAX COURT
LUISA DEAL, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12757-98. Filed October 25, 1999.
Luisa Deal, pro se.
Yvonne M. Peters
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: Respondent determined a
deficien…
PBGCRegulationsJan 1, 2017
e year of the proposed termination date, is $2,352.27 per month, payable in the form of a single life annuity at age 65. Because the participant is older than age 65, no adjustment is required under § 4022.23(c) based on the annuitant's age factor. The benefit form is a joint and survivor annuity (contingent basis), as…
IRCCourt RulingsNov 17, 2016
…35
2003 160,000 69,687 53,150
2004 165,000 71,633 54,811
2005 170,000 74,170 56,472
2006 175,000 76,352 58,133
In view of his computation pursuant to section 415(b)(2)(C) of lower reduced
benefit limits, respondent in the notice of deficiency further calculated allowable
deduction limits. Since respondent computed lowe…
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA).[352]
PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsDec 9, 2011
…ontracts in an amount equal to the Annuity
Value for purposes of Revenue Ruling 55-119, 1955-1 C.B. 352, and each Trust shall
recognize gain or loss as a result of such transfer in the tax year that includes such
transfer as provided therein.
2. Each Trust will recognize gain or loss as a result of the sale of its Part…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…ent years
Activity
Burden hours
Equivalent
burden cost
Burden hours Equivalent
burden cost
Legal
10,352
$1,649,488
0
$0
Total
10,352
1,649,488
0
0
For the added requirement of a written statement informing the investor of their right to obtain a written description of the financial institution's policies and procedures…
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967related by meaning
t-sharing trust. Our conclusion makes it unnecessary to consider respondent’s alternative argument that the deduction should be limited to $10,346.69. Section 401(a) and the regulations pursuant thereto require that the plan not discriminate in favor of employees who are officers, shareholders, or highly compensated em…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
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, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
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…
IRCCourt RulingsMay 28, 1962related by meaning
ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
IRCCourt RulingsNov 5, 1999
…unt No. 015-268675 was as
follows:
- 11 -
Date
Withdrawal
Deposit
Balance
8/27/85 $1,333.20 --- $53,352.07
8/27/85 50,000.00 --- 3,352.07
10/15/85 --- $1,127.20 4,479.27
11/25/85 --- 1,333.20 5,812.47
12/03/85 5,500.00 673.91 986.38
1/13/86 14,500.00 13,654.49 140.87
4/14/86 --- 1,059.80 1,200.67
10/07/86 3.00 1,028.36…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsNov 4, 1998
…03(h), 706(g)(1), and
717(a), (b), and (c) of title VII of the Civil Rights Act of
1964, Pub. L. 88-352, 78 Stat. 254, 257, 261, as amended. The
opinion concludes that “employee” as used in section 704(a) of
Pub. L. 88-352, 78 Stat. 257, is ambiguous and further concludes
that the purposes of that section 704(a) would …
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…
IRCCourt RulingsJun 9, 1965
…ed goods.. 353,677.93 111,687.77 324,986.69 353,677.93 111, 687.77 324,986.69
Total inventory.. 790,352.39 790,352.39
DEFERRED CHARGES
Factory supplies.— Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14
Total deferred charges. 13,049.01 13,049.01
FIXED ASSETS
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
IRCCourt RulingsApr 15, 1991
…. 1982).
United States v. Williams, 737 F.2d 594 (7th Cir. 1984).
O’Malley v. Commissioner, 91 T.C. 352 (1988).
Since we have previously held petitioner’s legal expenses to be personal in nature, petitioner is estopped from now arguing that the legal fees were incurred in his capacity as fiduciary of the pension plan. …
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…