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92 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  2. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997★ strong match
    …ck v. Commissioner , T.C. Memo. 1993-582, affd. per curiam sub nom. Butts v. Commissioner , 49 F.3d 713 (11th Cir. 1995); Butts v. Commissioner , T.C. Memo. 1993-478, affd. per curiam 49 F.3d 713 (11th Cir. 1995) (the Allstate cases). The parties agree that the facts of this case are essentially indistinguishable from …
  3. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    …pril 15, 2017, and the remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713.(iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan's effectiv…
  4. T.C. Memo. 2021-107 — Gayle Gaston v. Commissioner
    IRCCourt RulingsSep 2, 2021
    …m inant, prim ary or principal objective” of m a king a profit, Wolf v. Com m issioner, 4 F.3d 709, 713 (9th Cir. 1993), aff ’g T.C. Mem o. 1991- 212, and (2) the taxpayer can substantiate the reported expense as an ordinary and necessary business expense, see sec. 183; Dreicer v. Com m issioner, 78 T.C. 642, 645 (1982…
  5. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    tribution with respect to an employee under subparagraph (A) only if— (i) such amount is received on or after the employee has attained age 591/2, and (ii) the taxpayer elects for the taxable year to have all such amounts received during such taxable year so treated. Not more than 1 election may be made under this subp…
  6. 80 FR 54374 — Determination of Minimum Required Pension Contributions
    IRCFinal Rules (FR)Sep 9, 2015
    e remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713. (iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan's effective interest rate for …
  7. T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont…
    IRCTreasury DecisionsSep 28, 2015
    …pril 15, 2017, and the remaining contribution due on April 15, 2017 is $25,000 minus $17,287, or $7,713. (iii) The interest adjustments in paragraph (ii) of this Example 3 are based on the effective interest rate even if that rate is not determined by the time that the required installment is due. If the plan’s effecti…
  8. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  9. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  10. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …tributions were made to an unqualified trust and not at the time of distribution." Fazi I, supra at 713. Respondent conceded in Fazi I that the merged amount would be taxable in 1986, rather than 1987. Petitioners, in Fazi I,
  11. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  12. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ccord Grajales, 156 T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68, Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional amount” within the meaning of section 6751(c). To implement the foregoing, An order will be issued g…
  13. 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…
  14. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  15. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
    IRCTreasury DecisionsSep 18, 2006related by meaning
    INCOME TAX Notice 2006-76 Notice 2006-76 This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
  16. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  17. 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…
  18. I.R.C. § 401(d) — Qualified pension, profit-sharing, and stock bonus plans
    IRCCode / StatuteJan 6, 2025
    … with respect to which such plan is established. [(e) Repealed. Pub. L. 98–369, div. A, title VII, §713(d)(3), July 18, 1984, 98 Stat. 958]
  19. 77 T.C. 477 — Chapman v. Commissioner
    IRCCourt RulingsAug 24, 1981related by meaning
    s otherwise indicated. Unless otherwise indicated, any reference to "Rules” shall be deemed to refer to the Tax Court Rules of Practice and Procedure. The Court has concluded that the post-trial procedures of Rule 182 are not applicable in these particular circumstances. This conclusion is based on the authority of the…
  20. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …vings , in order to deduct expenses under section 162 or 212 . 20 Wolf v. Commissioner, 4 F.3d 709, 713 (9th Cir. 1993) , aff ’ g T.C. Memo. 1991 - 212; Indep. Elec. Supply, Inc. v. Commissioner, 781 F.2d 724, 726 (9th Cir. 1986) , aff ’ g Lahr v. Commissioner, T.C. Memo. 1984-472 ; Sherman v. Commissioner, T.C. Memo. …