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1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
   IRCCourt RulingsMar 5, 2018related by meaning
   r correctness of legal standard), rev'g T.C. Memo. 1992-596. - 89 - before us: The Mazzeis used an FSC, not a DISC, and not a C corporation or an LLC. The majority acknowledges, see op. Ct. p. 32, that the Code requires us to respect certain payments a business makes to an FSC in exchange for nothing, even though we wo…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   nsolidated group as “consistent with the 1986 statutory amendment” and “supported by the language of the 1986 amendment.” Such allocation is in fact 1 We also note that, if we were to agree with 3M in the present case, we would be giving primary weight to a Brazilian legal restriction that was not publicly promulgated,…
3. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
   IRCCourt RulingsSep 25, 1996
   … reality, to which we have refused to give effect. For example, in Drobny v. Commissioner , 86 T.C. 1326 (1986),
4. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   IRCCourt RulingsFeb 18, 1997related by meaning
   l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
5. 84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
   IRCFinal Rules (FR)Jun 20, 2019
   …te at www.cms.hhs.gov/​PaperworkReductionActof1995, or call the Reports Clearance Office at 410-786-1326. HHS invites public comments on these information collection requirements. If you wish to comment, please identify the rule (CMS-9918-F), the ICR's CFR citation, CMS ID number, and OMB control number. Comments and r…
6. 66 T.C. 324 — Bianchi v. Commissioner
   IRCCourt RulingsMay 20, 1976related by meaning
   ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
7. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
   IRCCourt RulingsNov 4, 1976
   …9 F.2d 390, 393 (2d Cir.), reversing 48 T.C. 75; Cornell-Young Co. v. United States, supra at 1324, 1326; John Duguid & Sons, Inc. v. United States, 278 F.Supp. 101, 106 (N.D. N.Y.).
8. 78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act
   IRCProposed Rules (FR)Proposed Feb 6, 2013
   …MS document identifier, to paperwork@cms.hhs.gov, or call the Reports Clearance Office at (410) 786-1326.
9. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
   IRCCourt RulingsMar 25, 2013
   …ddressing the reasonableness of compensation. Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d at 1326; Charles Schneider - 25 - [*25] & Co. v. Commissioner, 500 F.2d at 152. Corporations, however, are not required to pay dividends. Owensby & Kritikos, Inc. v Commissioner, 819 F.2d at 1326. The prime indicator of the…
10. 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…
11. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
12. Court of Appeals for the Seventh Circuit — Central States, SE and SW Areas Pension Fund v. Consumers Concrete Corp.
    ERISACourt RulingsSep 17, 2026
    …o keep track of and standardize.” Pulsifer , 601 U.S. at 149. See Perfection Bakeries, 147 F.4th at 1326–27 (Brasher, J., dissenting) (“‘Withdrawal liability’ is defined by the statute as ‘the amount determined’ by the four -step process in section 1381.”). Additionally, the Fund points to § 1381(a)’s language that “the…
13. 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…
14. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
15. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …te at www.cms.hhs.gov/​PaperworkReductionActof1995, or call the Reports Clearance Office at 410-786-1326. If you wish to comment, please submit your comments electronically as specified in the ADDRESSES section of these proposed rules and identify the rule (CMS-9915-P), the ICR's CFR citation, CMS ID number, and OMB co…
16. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
17. 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…
18. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …te at www.cms.hhs.gov/​PaperworkReductionActof1995, or call the Reports Clearance Office at 410-786-1326. E. Paperwork Reduction Act—Department of Labor and Department of the Treasury
19. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
20. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    … visit www.cms.hhs.gov/​PaperworkReductionActof1995 or call the Reports Clearance Office at 410-786-1326.