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1. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
   IRCCourt RulingsAug 24, 2000
   T.C. Memo. 2000-266 UNITED STATES TAX COURT LESTER L. AND SUSAN P. SAMFORD, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13597-91. Filed August 24, 2000. Thomas E. Redding , for petitioners. Robert E. Marum , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge …
2. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
   IRCCourt RulingsSep 29, 2009
   … an S corporation (Taproot) ." This reading seems to make sense . Taproot cited . Revenue Ruling 66-266, . 1966-2 C .B . 356, and Priv . Ltr . Rul . 86-05-028 (Nov . 4, 1985) to support its reading of the regulation . The Commissioner seized on these pre-1995 citations and urged that they be read as limited to custodia…
3. 91 FR 27140 — Excepted Fertility Benefits
   IRCProposed Rules (FR)Proposed May 13, 2026
   …imate that there are 32,545 State and local government employer-sponsored plans, in addition to 490,266 private sector employer-sponsored plans, that could be affected by these proposed rules. In total, these proposed rules are expected to affect 522,811 plans and entities. These calculations are detailed in the table …
4. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
   IRCCourt RulingsApr 2, 2024related by meaning
   , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
5. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   IRCCourt RulingsFeb 18, 1997★ strong match
   …d)(4), see Childs v. Commissioner , T.C. Memo. 1996-267; Thompson v. Commissioner , T.C. Memo. 1996-266. 9 Insofar as petitioner Elam Campbell might otherwise be concerned, see sec. 4980A(b); Johnson v. Commissioner , 74 T.C. 1057, 1062 (1980), affd. 661 F.2d 53 (5th Cir. 1981). The Parties' Concessions The distributio…
6. 80 FR 70170 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
   PBGCFinal Rules (FR)Nov 13, 2015
   …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 266, 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…
7. 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…
8. 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…
9. Treas. Reg. § 1.401(a)-20(b) — Requirements of qualified joint and survivor annuity and qualified preretirement survivor annuity.
   IRCRegulationsMay 18, 2016
   …of the Employee Retirement Income Security Act of 1974. See H.R. Rep. No. 1280, 93d Cong., 2d Sess. 266 (1974).
10. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    statement within 90 days. Therefore, aRespondent argues that since the TSP did not accept petitioner's late August payment, petitioner never made this payment. We base our holding on.the fact athat petitioner failed to pay the remaining balance before the end of the cure period or notify the TSP of his reinstatement. -…
11. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
12. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
13. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …s., Inc., 509 U.S. 579, 593-594 (1993); see Amorgianos v. Nat'l R.R. Passenger Corp., 303 F.3d 256, 266 (2d Cir. 2002). - 33 - and brackets omitted) (quoting Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999)). The inquiry "will necessarily vary from case to case". Amorgianos, 303 F.3d at 266. Essentially, Ms. Ho's…
14. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
15. T.C. Summary Opinion 2003-59 — Anthony V. & Sandra K. Margavio v. Commissioner
    IRCCourt RulingsMay 22, 2003
    … the notice of deficiency, respondent determined that petitioner had failed to include $15,551 ($31,266 taxable amount less the $15,715 reported by petitioners) of taxable pension annuity income on their 1998 return. We consider the $1 - 3 - discrepancy between the amount of $31,267 shown on the 1998 Form 1099-R and th…
16. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
17. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    0,100. 40 341, 117. 36 438, 983. 04 Less royalties_ 22, 895. 89 5, 266. 05 17, 629. 84 Gross income — adjusted_ 757, 204. 51 335, 851. 31 421, 353. 20 Direct costs_ 442, 809. 13 Subtotal_ 314, 395. 38 Administration expense at 3.3%_ 25, 743. 31 50% of net income_ 288, 652. 07 15% of adjusted gross income from feldspar_…
18. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …es of all revenue streams with affiliated pharmacy-related entities can result in reduced premiums.[266] PBMs may also utilize rebate aggregators to negotiate and collect rebates from drug manufacturers, whose extracted fees have been estimated to have doubled between 2018 and 2022. PBMs that use affiliated rebate aggr…
19. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
20. 81 FR 85190 — Update to Minimum Present Value Requirements for Defined Benefit Plan Distributions
    IRCProposed Rules (FR)Proposed Nov 25, 2016
    …of this paragraph (d)(3)(ii) (taking the probability of death only after age 65 into account) is 11.266 for a participant age 60. To satisfy the requirement of section 417(e)(3) and this paragraph (d), the single-sum payment received by Q with respect to the employee-provided portion of the accrued benefit cannot be le…