Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 92 T.C. 351 (not yet in the library — opens the official source)
87 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  2. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    eives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. A "qualified retirement pl…
  3. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    hich is owned by U.S. Corp, in a transaction qualifying under section 351. U.S. Corp and DS are members of the same consolidated group. (ii) Analysis. Pursuant to § 1.987-2(c)(2)(i) and (ii), as a result of the deemed exchange of the assets and liabilities of Business A for DS stock in a section 351 transaction, Busine…
  4. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  5. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ured group market, where prescription drugs benefits are bundled rather than separately carved out.[351]
  6. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …3.01(22) of Rev. Proc. 98-3, 1998-1 I.R.B. 102-3, the Service will not rule on the application of § 351 of the Code to an exchange of stock in the formation of a holding company. However, the Service has the discretion to rule on significant subissues that must be resolved to determine whether the transaction qualifies…
  7. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …Benefits Trust" (E.I.N. 86-6184818): 10 1990 1991 1992 1993 1994 Interest income $232,158 $372,992 $351,722 $106,927 $92,464 Other income: forfeitures --- 9,453 --- --- --- Other income: refund trustee fees --- --- --- --- 4,012 Tax exempt income 55,467 34,812 295,340 118,797 14,498 Total income 232,158 382,445 351,722…
  8. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
  9. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …S-Corp. stock, as was necessary to qualify for nonrecognition of income under - 19 - [*19] sections 351(a) and 368(c). Respondent urges that petitioners are improperly "trying to have it both ways." We are unpersuaded by this argument. Respondent does not contend that the section 351 exchange was invalid and has not so…
  10. Treas. Reg. § 54.9825-3T — Definitions (temporary).
    IRCRegulationsDec 23, 2021
    …der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
  11. 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…
  12. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  13. 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…
  14. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  15. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  16. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    …elling shareholders includes an installment obligation of the purchasing entity. (33) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same …
  17. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
  18. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005
    …elling shareholders includes an installment obligation of the purchasing entity. (31) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same …
  19. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …d a $17,070 insurance expense deduction on their 2014 Schedule C1. On brief respondent concedes $12,351 of that amount but contends that petitioners failed to substantiate the remaining $4,719. - 38 - [*38] The record does not establish that BJW had insurance expenses in excess of the amount respondent has conceded. On…
  20. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…