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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … inv alid under Chevron step 1 because Commissioner v. First Security Bank of Utah, N.A. , 405 U.S. 394 (1972), and its progenitor and progeny held that
2. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996★ strong match
   begin with section 4973. Section 4973 Section 4973(a) imposes a 6-percent excise tax on excess contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as a deduction under section 219 (computed without regard to section - 27 - 219(g)), exclusive of amounts p…
3. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
   IRCTreasury DecisionsAug 28, 2006related by meaning
   n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
4. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
   IRCCourt RulingsOct 9, 1997related by meaning
   nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
5. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
   IRCCourt RulingsSep 22, 1998related by meaning
   ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
6. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
   IRCProposed Rules (FR)Proposed Dec 30, 2014
   …lent cost SBC with Coverage Examples to Group Health Plan: Renewal or Application 527,328 263,664 4,394 $130,074 4,394 $130,074 Sub-total 527,328 263,664 4,394 130,074 4,394 130,074 SBC with Coverage Examples To Participants and Beneficiaries: Upon Application or Eligibility 2,030,000 1,015,000 16,917 500,733 16,917 50…
7. 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…
8. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
   IRCRegulationsSep 9, 2016
   …iated with Participant E's assumed age 50 withdrawal benefit in the 2009 actuarial valuation is $67,394.12. This reflects the sum of each year's expected payments, discounted at the yield rates described in paragraph (i) of this Example 11, as shown below: Age Maturity Yield rate Present value 65 19.5 6.97% $5,897.88 6…
9. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
   IRCCourt RulingsMar 10, 2020
   …nable justification for the statutory distinction. McDonald v. Board of Election Com'rs of Chicago, 394 U.S. 802, 809 (1969). Estate of Kunze v. Commissioner, 233 F.3d 948, 954 (7th Cir. 2000), § T.C. Memo. 1999-344.5 This Court follows the same framework in evaluating equal protection claims regarding statutes affecti…
10. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …486 47,539,329 D. Nondeductible contribution from prior years (O from prior year) --- 22,034,781 14,394,743 14,426,384 E. Net value of assets 1 --- 9,827,240 16,953,743 33,112,945 F. Present value future normal costs 2 39,673,488 65,389,545 93,638,363 99,428,929 G. Average present value of future service 4.81 6.63 7.26…
11. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
12. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …Cir. 1989); Cozzi v. Commissioner , 88 T.C. 435, 443-444, (1987); Jackson v. Commissioner , 73 T.C. 394, 401 (1979); Westby v. Commissioner , T.C. Memo. 2004-179. In any case in which both parties have satisfied their burdens of production by offering some evidence, then the party whose position is supported by the wei…
13. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    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…
14. Court of Appeals for the Seventh Circuit — Central States, SE and SW Areas Pension Fund v. Consumers Concrete Corp.
    ERISACourt RulingsSep 17, 2026
    …s and litigants may properly resort for guidance.” Loper Bright Enters. v. Raimondo , 603 U.S. 369, 394 (2024) (quoting Skidmore v. Swift & Co. , 323 U.S. 134, 140 (1944)). III. Conclusion
15. T.C. Summary Opinion 2017-51 — Arthur Dulik, Jr. & Ellen B. Kugler Dulik v. Commissioner
    IRCCourt RulingsJul 13, 2017
    …cedure. 2Petitioners conceded that the amount of the taxable dividend they received in 2010 was $20,394, and not $18,657 as reported on the return; thus they failed to report $1,737 ($20,394 - $18,657 = $1,737) in taxable dividend income. - 3 - Background Some of the facts have been stipulated and are so found. The sti…
16. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
17. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    quirements of section 7121. See Urbano v. Commissioner, 122 T.C. at 393-394. Section 7121 and the regulations thereunder set forth the exclusive means and procedures by which an agreement between the IRS and a taxpayer concerning the latter's tax liability may be accorded finality. See, e.g., Urbano v. Commissioner, 12…
18. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …e receipt of benefits is the determinative factor); see also Weber v. Commissioner, 103 T.C. at 393-394; Colvin v. Commissioner, T.C. Memo. 2007-157, affd. 285 Fed. Appx. 157 (5th Cir. 2008). Petitioner's access to and receipt of employee benefits at the BCG further supports a finding that he was a common law employee.…
19. 29 C.F.R. § 4907.103(4) — Definitions.
    PBGCRegulationsJan 1, 2017
    …4907.140. Section 504 means section 504 of the Rehabilitation Act of 1973 (Pub. L. 93-112, 87 Stat. 394 (29 U.S.C. 794)), as amended by the Rehabilitation Act Amendments of 1974 (Pub. L. 93-516, 88 Stat. 1617), and the Rehabilitation, Comprehensive Services, and Developmental Disabilities Amendments of 1978 (Pub. L. 95…
20. 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 …