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…
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…
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…
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…
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…
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]
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…
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…
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…
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…
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…
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 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…
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…
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.…
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 …
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…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
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…