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80 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971★ strong match
    …3 (1926); Burnet v. S. & L. Bldg. Corp., 288 U.S. 406, 413-414; Nuckolls v. United States, 76 F. 2d 357, 359 (C.A. 10) ; Everett Pozzi, 49 T.C. 119, 126; Lewis M. Ludlow, 36 T.C. 102, 107-108; Thomas F. Prendergast, Executor, 22 B.T.A. 1259, 1262. The effect of reporting sales proceeds under the installment method is t…
  2. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  3. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018★ strong match
    1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171 (1931)), aKg T.C. Memo. 1982-209. With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed below, we reject petitioners' broadest argument--that the substance doctrines have no…
  4. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …respect to section 511 unrelated busines s 6The American Jobs Creation Act of 2004 :, Pub . L . 108-357, sec . 233(a), 118 Stat . 1434, added that provision to sec . . 1361(c)(2)(A) . The added clause applies only to bank stock held in an IRA or a Roth IRA as of Oct . 22, 2004 . Because of the temporal limitation a ban…
  5. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    … where he ‘ obtains the fruition of the economic gain which has already accrued to him ’ . ” Id. at 357 ( quoting Carione v. United States, 368 F. Supp. 2d 186, 194 (E.D.N.Y. 2005)) . Thus the Court, like the d istrict c ourt, relied on caselaw holding that an individual should be taxed on an economic benefit conferred…
  6. IRCCourt RulingsAug 3, 1979★ strong match
    …involves an otherwise suspect classification. Reed v. Reed, 404 U.S. 71 (1971); Speiser v. Randall, 357 U.S. 513, 518 (1958); First Unit. Church v. Los Angeles, 357 U.S. 545, 548 (1958); Grosjean v. American Press Co., 297 U.S. 233, 250 (1936); Moritz v. Commissioner, 469 F.2d 466 (10th Cir. 1972), revg. 55 T.C. 113 (1…
  7. 100 T.C. 216; 100 T.C. No. 15 — Halliburton Co. v. Commissioner
    IRCCourt RulingsMar 24, 1993
    drop in participation had occurred during the year. Laarman & Hildebrandt, Tax Management Portfolio 357, Plan Terminations and Mergers A-18(2) (1986). Respondent as well has indicated acceptance of such position. In G.C.M. 39,344 (Oct. 16, 1984), it was concluded that a partial termination did not occur where the drop …
  8. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  9. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    ons are includible in petitioner's gross income for 1995. Petitioner contends that they are not. In support of that contention, petitioner argues that there was gross negligence by the [Family] court and my ex-wife's lawyer that caused the money to be removed from the IRA. * * * * * * * * * * This was a forced withdraw…
  10. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987
    …t errors because the taxpayer failed to report an item on the return. Colony, Inc. v. Commissioner, 357 U.S. 28 (1958). The Court stated that the extended statute of limitations applies when “the return on its face provides no clue as to the existence of the omitted item.” 357 U.S. at 36.
  11. 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…
  12. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  13. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ith 500 or more employees, 37 percent had no idea how much of PBM negotiated rebates they received.[357] Responsible plan fiduciaries of small self-insured group health plans, in particular, often have limited access to pricing information compared to larger self-insured group health plans, which receive higher retail …
  14. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  15. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    … in the amount of $377,225, which amount exceeded the amount of cash held by the VEBA ($19,908) by $357,317. There is no evidence in the record to show that, as of the close of the taxable year 1984, petitioner was liable for any amount in excess of $357,317. Thus, even if an enforceable receivable constituted an asset…
  16. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  17. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  18. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-263 UNITED STATES TAX COURT RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v . COMMISSI…
  19. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  20. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …he Supreme Court resolved a conflict between (1) its 1958 opinion in Colony, Inc. v. Commissioner , 357 U.S. 28 (1958) , and (2) a Treasury regulation promulgated in 2010. 26 C.F.R. sec. 301.6501(e)-1(a)(1)(iii) (2011). Colony had interpreted a provision of the Internal Revenue Code of 1939. Home Concrete & Supply , 56…