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85 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012
    ed these alternative theories and now argues solely for the application of sec. 269 to disallow petitioners' $2,969,000 claimed loss deduction. - 18 - OPINION Section 269(a) provides that if a taxpayer acquires control of the stock in a corporation and the principal purpose for the acquisition is the evasion or avoidan…
  2. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    … transactions, as structured, reflected arm’s-length charges for the services performed. 2. Section 269 The second issue is whether respondent properly utilized his authority under section 269 to allocate A & R’s income and deductions to Tahoe City Disposal and Kings Beach Disposal. Section 269 is available— (a) In Gen…
  3. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …4 2. Actuarial value of assets VEBA -0- 30,736,554 30,176,217 39,940,676 401(h) -0- 1,125,467 1,172,269 7,598,653 Total -0- 31,862,021 31,348,486 47,539,329 3. Actuarial present value of future normal costs [1-2] 1 13,361,588 43,354,764 79,243,620 85,002,545 4. Actuarial present value of future service 4.81 6.63 7.26 7…
  4. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …n attaches new legal consequences to events completed before its enactment.” Landgraf , 511 U.S. at 269 – 70; see also id. at 291 (Scalia, J., concurring in the judgments) (“The critical issue . . . [when conducting retroactivity analysis is] what is the relevant activity that the rule regulates.”). As the foregoing di…
  5. T.C. Summary Opinion 2008-163 — Kenneth F. Reinert v. Commissioner
    IRCCourt RulingsDec 23, 2008
    …ce contract , he decided to allow the termination . In response , Northwestern sent petitioner a $1,269 .57 check representing the difference between the $29,933 . 78 cash value of the policy and petitioner ' s $28,664 .21 outstanding loan ( including interest accretions) against the cash value . Northwestern sent peti…
  6. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …petition, ultimately contributing to higher costs for self-insured group health plans and patients.[269]
  7. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  8. 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…
  9. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  10. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    Posner, J.) (ruling that the attribution rules of section 318 "don't apply to section 269; for section 318 applies only when expressly made applicable * * *, and it hasn't been made expressly applicable to section 269, which anyway is not in subchapter C"). Petitioners cite Boise Cascade Corp. v. United States, 329 F.3…
  11. 81 FR 7454 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Feb 12, 2016
    …: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, add Rate Set 269 to the table to read as follows: Appendix B to Part 4022—Lump Sum Interest Rates For PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annuities (percent) On o…
  12. 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…
  13. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016★ strong match
    …002 $10,081 $2,268.22 $2,520.25 2003 19,401 4,365.22 4,850.25 2004 26,498 5,962.05 6,624.50 2005 25,269 5,685.52 6,317.25 2006 23,894 5,376.15 5,973.50 ¹Unless otherwise indicated, section references are to the Internal Revenue Code (Code) applicable for the years at issue. Rule references are to the Tax Court Rules of…
  14. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …es on transactions under the authority given to him in other Code sections. For example, in section 269 the Commissioner is given substantial discretionary authority to label a transaction as engaged in for the principal purpose of tax evasion or avoidance and to disallow related deductions. The tax "evasion" or "avoid…
  15. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    eems that sale to be a prohibited transaction for purposes of the section 4975(a) excise tax which is not excused by any applicable exception. OPINION Section 4975, as added to the Internal Revenue Code by Title II of the Employee Retirement Income Security Act of 1974. imposes an excise tax on prohibited transactions.…
  16. 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 …
  17. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ware that she had been a leased employee. Machise considered the amount spent by W & A, some $3,586,269 in 1987, as the amount of payroll costs incurred under the employee leasing agreement. In 1987, W & A reported a loss of $3,586,269, and a separate item of portfolio income of $113. On their individual income tax ret…
  18. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  19. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  20. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…