IRCCourt RulingsSep 18, 1996related by meaning
ies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), petitioner is not liable for the excise tax
imposed by section 4980A for 1989. For 1990, petitioner withdrew an amount in excess of
$150,000 from his IRA with First National. Accordingly,
- 28 -
20
See supra
note 15 and accompanying text. Further, …
IRCCourt RulingsFeb 9, 2023★ strong match
…d Appropriations Act, 2018, Pub. L. No. 115-141, div. U, sec. 401(d)(1)(D)(viii)(III), 132 Stat. at 1207. Section 367(d)(4)
provides:
220
For purposes of this subsection, the term “intang ible
property” means any --
(A) patent, invention, formula, process,
design, pattern, or know-how,
(B) copyright, literary, musical,…
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…
ERISACourt RulingsSep 29, 2026
…e don’t resolve
inference s in favor of either party. Ian C. v. UnitedHealthcare Ins. Co.,
87 F.4th 1207, 1217 (10th Cir. 2023).
Appellate Case: 25-3160 Document: 60-1 Date Filed: 09/29/2026 Page: 6
7
Such discretion exists here;
3
so we must uphold the plan
administrator’s interpretation unless it is arbitrary and cap…
IRCCourt RulingsMar 9, 2011
…porate entity for tax purposes if it were not a DISC. Addison Intl.,
Inc. v. Commissioner,. 90 T.C. 1207 (1988), affd. 887 F.2d 660
(6th Cir. 1989); Jet Research, Inc. v.+ Commiessioner,- T.C. Memo.
1990-463; see also sec. 1.992-1(a)s, Income Tax Regs. ".The DISC
may be no more than a shell corporation, which performs …
IRCCourt RulingsJun 24, 2003related by meaning
T.C. Summary Opinion 2003-83
UNITED STATES TAX COURT
MANUEL FRANCISCO PALOMO AND JANE LYON POTTER, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7010-01S. Filed June 24, 2003.
Manuel Francisco Palomo
, for petitioners.
Carina Campobasso
, for respondent.
DEAN, Special Trial Judge
: This case w…
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 RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…er year. HHS will amend the information collection currently approved under OMB control number 0938-1207 (Medicaid and Children's Health Insurance Programs: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes, and Premiums and Cost Sharing; Exchanges: Eligibili…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMar 5, 2018★ strong match
…I, 848 F.3d at 782; Addison
Int'l, Inc. v. Commissioner, 887 F.2d 660, 666 (6th Cir. 1989), 90 T.C. 1207
(1988); Hellweg v. Commissioner, T.C. Memo. 2011-58, 2011 WL 821090, at *5.
FSCs were very similar--barely-there entities through which businesses could
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMay 22, 2025
…solidated
Appropriations Act, 2018, Pub. L. No. 115- 141, § 401(d)(1)(D)(viii)(III), 132 Stat. 348,
1207. The definition in section 367(d)(4) differs in style but not substance from the
2017 definition in section 936(h)(3)(B).
120
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
IRCCourt RulingsOct 10, 2018
…resentation to the drawee (i.e.,
the bank in this case). Estate of Hubbell v. Commissioner, 10 T.C. 1207, 1208
(1948) (citing Eagleton v. Commissioner, 35 B.T.A. 551 (1937), af[d, 97 F.2d 62
(8th Cir. 1938)); see also, e.g., Muldrow v. Tex. Frozen Foods, Inc., 299 S.W.2d
275, 277-278 (Tex. 1957) ("[I]t is well settled …
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsAug 27, 2008
…ency ." Cupp v . Commissioner , 65 T .C . 68, 83 (1975), affd . without published opinion 559 F .2d 1207 (3d Cir .
1977) . More generally and with respect to petitioner's second
argument, the Court will not look behind a notice of deficiency
to question the Commissioner's procedures leading to the
determination of a de…
IRCCourt RulingsJan 2, 2025
…trive a fictional debt” (quoting United States v. Uneco, Inc. ( In re Uneco, Inc. ), 532 F.2d 1204, 1207 (8th Cir. 1976))), aff’d , 521 F. App’x 476 (6th Cir.
2013).
25
[* 25] any credible documents in the record. For example, they claim
that an independent actuary firm valued NRSP Management at
$75 million in 2009. Th…