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 11 T.C. 552 (not yet in the library — opens the official source)
89 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
    IRCFinal Rules (FR)Jun 20, 2019
    …H employs 17 full-time employees and 10 part-time employees whose work site is in rating area 1 and 552 full-time employees whose work site is in rating area 2. For 2020, Plan Sponsor H offers its 17 full-time employees in rating area 1 a traditional group health plan and each of its 552 full-time employees in rating a…
  2. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012★ strong match
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  3. Treas. Reg. § 54.9802-4(f)(1)(ix) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover…
    IRCRegulationsAug 19, 2019
    …H employs 17 full-time employees and 10 part-time employees whose work site is in rating area 1 and 552 full-time employees whose work site is in rating area 2. For 2020, Plan Sponsor H offers its 17 full-time employees in rating area 1 a traditional group health plan and each of its 552 full-time employees in rating a…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  5. T.C. Summary Opinion 2006-106 — Christine L. Gibbons v. Commissioner
    IRCCourt RulingsJul 13, 2006
    …uring the year 2002, petitioner, as an employee and a participant in the pension plan, withdrew $67,552 .64 from the plan, the proceeds of which were to fund her daughter's higher education expenses . On her Federal income tax return for 2002, petitioner reported the entire amount of the pension plan withdrawal as inco…
  6. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015related by meaning
    report the initial retirement distribution of $4,984 from State Street; that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of the retirement distribution includible in gross income; and that he was liable for an a…
  7. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  8. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011★ strong match
    …'s qualified export sales (ADF commission payments). ADF reported qualified export sales of $10,308,552 in
  9. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996★ strong match
    … 80 during 1980. MIT 80, under its cash method of accounting, accordingly reported a loss of $2,247,552. The loss consisted of the following: Salaries and wages $456,618 Rent--independent contractors 1,673,742 Payroll taxes 35,877 Pension plan 37,109 Insurance 41,823 Professional fees 2,383 Total 2,247,552 - 21 - 7 The…
  10. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    …rivate foundations. See H. Rept. 91-413 (Part 1), 4, 20-21 (1969), 1969-3 C.B 202, 214; S. Rept. 91-552, 6, 28-29 (1969), 1969-3 C.B. 426, 442-443; also see Staff of the Joint Committee on Internal Revenue Taxation, General Explanation of the Tax Reform Act of 1969 (hereinafter sometimes referred to as the TRA '69 Blue…
  11. 88 FR 74386 — Disclosure of Records
    IRCProposed Rules (FR)Proposed Oct 31, 2023
    …tinues to read as follows: Authority: 80 Stat. 379; sec. 3, 60 Stat. 238, as amended; 5 U.S.C. 201, 552. 2. Add subpart A before § 323.1; 3. Revise the first sentence of § 323.1; and 4. Add subpart B after § 323.5. The additions and revision read as follows: PART 323—DISCLOSURE OF RECORDS Authority: 80 Stat. 379; sec. …
  12. 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…
  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. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …nd the health benefit plan. Back to Citation 86.  18 U.S.C. 1836(b). Back to Citation 87.  5 U.S.C. 552. Back to Citation 88.  18 U.S.C. 1839(5)-(6). Back to Citation 89.  5 U.S.C. 552. Back to Citation 90.  5 U.S.C. 552(b)(4). Back to Citation 91.  42 U.S.C. 1320b-23(c). Back to Citation 92.  42 U.S.C. 300gg(18)(e). B…
  15. 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…
  16. T.C. Memo. 2011-2 — Michael C. Hollen, D.D.S., P.C. v. Commissioner
    IRCCourt RulingsJan 4, 2011★ strong match
    discretion. Under this a standard, petitioner must persuade the Court that respondent's determination was unreasonable, arbitrary, or capricious. See Buzzetta Constr. Corp. v. Commissioner, 92 T.C. 641, 648 (1989) . Petitioner has failed.to do so. Section 401(a) lists requirements which must be met in order for a.trus…
  17. Treas. Reg. § 1.401(a)(4)-13(c)(6) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …nd has covered compensation of $32,000. Employee M's accrued benefit as of December 31, 1995, is $4,552, the greater of—(1) $4,552, the sum of Employee M's accrued benefit frozen as of December 31, 1994, ($4,200) and the amended formula applied to Employee M's years of service after 1994 ((0.75 percent × $32,000 × 1 ye…
  18. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …idered in default. The loan was repaid in 2000 by an offsetting distribution from Plan 15105 of $15,552. During October or November of 2000, petitioner made a direct rollover of $286,390 from Plan 15105 into his Fidelity Investments IRA Rollover Account (Fidelity IRA). Fidelity
  19. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007
    …s order (QDRO) is includable in petitioner's 2002 taxable income ; (2) whether $8,119 .20 of the $9,552 in Social Security benefits received by petitioner in 2002 is includable in petitioner's 2002 taxable income ; (3) whether petitioner is liable for additions to tax under section 6651(a)(1)2 and (2) in the amounts of…
  20. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ncrete & Supply, LLC , 566 U.S. 478, 483 (2012) (citing John R. Sand & Gravel Co. v. United States, 552 U.S. 130, 139 (2008)). “ [ S ] tare decisis in respect to statutory interpretation has ‘special force,’ for ‘Congress remains free to alter what we have done.’” John R. Sand & Gravel Co. , 552 U.S. at 139 (quoting Pa…