Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 44 T.C. 660 (not yet in the library — opens the official source)
92 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  3. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …1 26,899 -0- 26,899 6,151 -0- 6,151 1980 25,952 -0- 25,952 5,900 -0- 5,900 1979 25,037 -0- 25,037 5,660 -0- 5,660 1978 24,155 -0- 24,155 5,429 -0- 5,429 1977 23,304 -0- 23,304 5,208 -0- 5,208 1976 22,484 -0- 22,484 4,996 -0- 4,996 1975 21,691 -0- 21,691 4,792 -0- 4,792 1974 20,927 -0- 20,927 4,597 -0- 4,597 1973 20,190…
  4. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
    IRCCourt RulingsJul 8, 2020
    …he amount petitioner actually paid during calendar 2016. On her return petitioner reported that $24,660 of her distributions was subject to the 10% additional tax under section 72(t). By negative implication this suggests that the expenses she believed to be exempt from the 10% additional tax totaled $29,840 ($54,500 -…
  5. 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…
  6. 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, …
  7. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …counts at California Federal Bank F.S.B. (CFB9263). During 1996 Mr. Zaklama withdrew $42,711 and $8,660 from his IRAs at Trust Company Bank (TCB5084) and Downey Savings & Loan (DSL5084),
  8. 98 T.C. 283; 98 T.C. No. 23 — Aronson v. Commissioner
    IRCCourt RulingsMar 18, 1992
    … to the return, petitioners stated the following: IRA distributions from— First Maryland S&L. *$ 10,660 Less amount rolled over . 10,660 Taxable..0 'The parties stipulated that the two checks received were $8,373 and $2,286 (total $10,659). There is nothing in the record to explain why petitioners reflected $10,660 in …
  9. Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”…
    IRCRevenue ProceduresOct 15, 2018
    …es 650 .03 Vesting Failures 657 .04 § 415 Failures 658 .05 Correction of Other Overpayment Failures 660 .06 § 401(a)(17) Failures 660 .07 Correction by Amendment 660 SECTION 3. EARNINGS ADJUSTMENT METHODS AND EXAMPLES .01 Earnings Adjustment Methods 661 .02 Examples. 663 PART I. INTRODUCTION TO EMPLOYEE PLANS COMPLIANC…
  10. 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…
  11. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …e appellate court affirmed. See Janangelo v. Treasury Inspector Gen. for Tax Admin. , 726 F. App’ x 660 ( 9th Cir. 2018). Mr. Janangelo’s FOI A litigation ended when the Supreme Court of the United States denied his petition for writ of certiorari. See Janangelo v. Treasury Inspector Gen. for Tax Admin . , 586 U.S. 999…
  12. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  13. T.C. Memo. 1996-189 — Marcus Wayne & Judith Caroline Ramsey v. Commissioner
    IRCCourt RulingsApr 18, 1996
    …a deduction for any of the claimed $6,201 automobile expenses. b. Interest Petitioners deducte d $1,660 as an interest expense. They presented evidence that they incurred this expense with regard to the Cadillac. Because the parties have stipulated that petitioner used the Cadillac 82 percent of the time for business u…
  14. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  15. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …ubdivision would require 33 transfer development credit s necessitating retirement of approximately 660 acres of qualifying coastal land. The record does not establish that such credits were available or reasonably obtainable. In addition, several proposed building pads appear to encroach upon ridgeline setback s and h…
  16. 76 FR 52442 — Summary of Benefits and Coverage and the Uniform Glossary
    IRCProposed Rules (FR)Proposed Aug 22, 2011
    …es SBC Requirements—Issuers 440 540,000 $18,000,000 $2,900,000 41,000,000 SBC Requirements—TPAs 750 660,000 23,000,000 3,700,000 49,000,000 Coverage Example Requirements—Issuers 440 140,000 7,600,000 1,500,000 41,000,000 Coverage Example Requirements—TPAs 750 240,000 13,000,000 1,800,000 49,000,000 Glossary Requests—Is…
  17. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
  18. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …3(b)(i); 2590.715-2715A3(b)(i); and 147.212(b)(1)(i) 0938-1372 1,959 16,325 3,199 6,266,188 848,390,660.00 0 848,390,660.00 §§ 54.9815-2715A3(b)(1)(ii); 2590.715-2715A3(b)(1)(ii); and 147.212(b)(1)(ii) 0938-1372 1,959 16,325 1,651 3,233,656 453,887,240.00 0 453,887,240.00 §§ 54.9815-2715A3(b)(1)(iii); 2590.715-2715A3(b…
  19. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961related by meaning
    ar 1954 under the provisions of section 404(a)(5), and section 1.404(a)-12, Income Tax Regs. On brief, petitioner states the “Issue To Be Decided” as— Where the petitioner obligated itself to pay to the widow of its deceased President an amount equivalent to the monthly salary of the deceased President for a period of …
  20. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …esembles their arguments against commonality. See Priddy v. Health Care Serv. Corp. , 870 F.3d 657, 660 (7th Cir. 2017) (the issue of “commonality and typicality tend to merge”) (quoting Gen. Tel. Co.