IRCCourt RulingsNov 25, 2013
T.C. Memo. 2013-271
UNITED STATES TAX COURT
CHRISTINE C. PETERSON AND ROGER V. PETERSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16263-11, 2068-12. Filed November 25, 2013.
Mitchell I. Horowitz and Micah G. Fogarty, for petitioners.
Andrew M. Tiktin and Timothy A. Sloane, for respondent.…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
IRCCourt RulingsSep 2, 2021
…sioner, 827 F.3d 968, 970-980 (11th Cir. 2016),
aff’g in part, dism issing in part T.C. Mem o. 2013-271.
- 4 -
[*4] After her retirem ent from Mary Kay, petitioner took up a num ber of non-
Mary Kay activities. First, through a wholly owned S corporation, Gayle Gaston,
Inc., petitioner began to sell jewelry to her form…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
$110 penalty amount plus the $165 statutory cap).
c. Section 702.271—Discrimination; Against Employees Who Bring Proceedings, Prohibition and Penalty Existing § 702.271(a)(1) provides that no employer or its agent may discharge or in any manner discriminate against an employee as to his or her employment because that …
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 RulingsJun 18, 1999
…5. On a Schedule C, petitioner reported gross
income (in the form of commissions) in the amount of $271 and
- 3 -
3
Petitioner questioned whether sec. 1.219-1, Income Tax
Regs., was in effect in 1993, the year in issue. Sec. 1.219-1,
Income Tax Regs., was promulgated by T.D. 7714, 1980-2 C.B. 83,
effective for taxable …
IRCCourt RulingsApr 12, 2011
…contract and (b) excludable from gross income.
- 16 -
Mr. Brown's investment in the contract was $8,271.76. He
paid total premiums of $44,205: $11,999 paid by check, $28,532
paid by loans, and $3,674 paid by applying dividends to premiums.
Before terminating the contract, he received $35,933.24 that was
excludable from…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…lower the average net retail price of prescription drugs, approximately 0.1 percent to 1.0 percent.[271]
Data from IQVIA indicates that expenditures for all prescription drugs from patients and issuers, less any rebates, totaled approximately $667.0 billion in 2022.[272]
The Department estimates that level-funded and s…
IRCCourt RulingsJan 9, 1985related by meaning
erest) on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsJun 16, 1987related by meaning
GOFFE, Judge:
The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
IRCCourt RulingsFeb 25, 2016
1,898, and a small amount of cancellation of indebtedness income,
for a net loss of $271,853. As sole shareholder, petitioner reported Strategies' net loss of $271,853 on a Schedule E, Supplemental Income and Loss, attached to his
2004 Form 1040.
For 2005 Strategies filed a Form 1120X, Amended U.S. Corporation
Income T…
84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019 ERISAFinal Rules (FR)Jan 23, 2019
…0, 15 FR 3174, 64 Stat. 1263; Secretary's Order 10-2009, 74 FR 58834.
§ § 702.204, 702.236, and 702.271
[Amended]
4. In the following table, for each paragraph indicated in the left column, remove the dollar amount or date indicated in the middle column from wherever it appears in the section or paragraph and add in it…
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…
82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017 ERISAFinal Rules (FR)Jan 18, 2017
…50, 15 FR 3174, 64 Stat. 1263; Secretary's Order 10-2009, 74 FR 58834.
§§ 702.204, 702.236, and 702.271
[Amended]
4. In the table below, for each paragraph indicated in the left column, remove the dollar amount or date indicated in the middle column from wherever it appears in the paragraph and add in its place the dol…
81 FR 22184 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Apr 15, 2016
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 271, as set forth below, is added to the table.
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 (pe…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
…0, 15 FR 3174, 64 Stat. 1263; Secretary's Order 10-2009, 74 FR 58834.
§ § 702.204, 702.236, and 702.271
[Amended]
4. In the following table, for each paragraph indicated in the left column, remove the dollar amount or date indicated in the middle column from wherever it appears in the section or paragraph and add in it…
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’ …
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…