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92 documents · 0.15sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-352 — Luisa Deal v. Commissioner
    IRCCourt RulingsOct 25, 1999
    T.C. Memo. 1999-352 UNITED STATES TAX COURT LUISA DEAL, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12757-98. Filed October 25, 1999. Luisa Deal, pro se. Yvonne M. Peters , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : Respondent determined a deficien…
  2. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …35 2003 160,000 69,687 53,150 2004 165,000 71,633 54,811 2005 170,000 74,170 56,472 2006 175,000 76,352 58,133 In view of his computation pursuant to section 415(b)(2)(C) of lower reduced benefit limits, respondent in the notice of deficiency further calculated allowable deduction limits. Since respondent computed lowe…
  3. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  4. PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 9, 2011
    …ontracts in an amount equal to the Annuity Value for purposes of Revenue Ruling 55-119, 1955-1 C.B. 352, and each Trust shall recognize gain or loss as a result of such transfer in the tax year that includes such transfer as provided therein. 2. Each Trust will recognize gain or loss as a result of the sale of its Part…
  5. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
  6. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    ic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F…
  7. 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…
  8. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …em were to be shut down. Law and Analysis : In Estate of Necastro v. Commissioner , T.C. Memo. 1994-352, the court considered the extent to which potential environmental clean up costs for solid waste were to be taken into account in determining the value of the decedent’s property. In applying the “willing buyer-willi…
  9. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    …unt No. 015-268675 was as follows: - 11 - Date Withdrawal Deposit Balance 8/27/85 $1,333.20 --- $53,352.07 8/27/85 50,000.00 --- 3,352.07 10/15/85 --- $1,127.20 4,479.27 11/25/85 --- 1,333.20 5,812.47 12/03/85 5,500.00 673.91 986.38 1/13/86 14,500.00 13,654.49 140.87 4/14/86 --- 1,059.80 1,200.67 10/07/86 3.00 1,028.36…
  10. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  11. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998
    …03(h), 706(g)(1), and 717(a), (b), and (c) of title VII of the Civil Rights Act of 1964, Pub. L. 88-352, 78 Stat. 254, 257, 261, as amended. The opinion concludes that “employee” as used in section 704(a) of Pub. L. 88-352, 78 Stat. 257, is ambiguous and further concludes that the purposes of that section 704(a) would …
  12. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …ed goods.. 353,677.93 111,687.77 324,986.69 353,677.93 111, 687.77 324,986.69 Total inventory.. 790,352.39 790,352.39 DEFERRED CHARGES Factory supplies.— Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14 Total deferred charges. 13,049.01 13,049.01 FIXED ASSETS
  13. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
  14. 96 T.C. 644; 96 T.C. No. 24 — O'Malley v. Commissioner
    IRCCourt RulingsApr 15, 1991
    …. 1982). United States v. Williams, 737 F.2d 594 (7th Cir. 1984). O’Malley v. Commissioner, 91 T.C. 352 (1988). Since we have previously held petitioner’s legal expenses to be personal in nature, petitioner is estopped from now arguing that the legal fees were incurred in his capacity as fiduciary of the pension plan. …
  15. 49 T.C. 174 — Armanco Productions, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1967related by meaning
    t-sharing trust. Our conclusion makes it unnecessary to consider respondent’s alternative argument that the deduction should be limited to $10,346.69. Section 401(a) and the regulations pursuant thereto require that the plan not discriminate in favor of employees who are officers, shareholders, or highly compensated em…
  16. 89 FR 64538 — Quality Control Standards for Automated Valuation Models
    IRCFinal Rules (FR)Aug 7, 2024
    …3909; 15 U.S.C. 1681s, 1681w, 6801 and 6805. 4. Add subpart O, consisting of §§ 225.350 through 225.352, to part 225 to read as follows: Subpart O—Quality Control Standards for Automated Valuation Models Used for Mortgage Lending Purposes 225.350 Authority, purpose and scope. 225.351 Definitions. 225.352 Quality contro…
  17. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  18. T.C. Memo. 2012-13 — John K. Goyak & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 11, 2012
    …and (5) was an ordinary expense. See Commissioner v. Lincoln Sav. & Loan Association, 403 U.S. 345, 352 (1971); Welch v. Helvering, 290 U.S. 111, 113-115 (1933). Whether an expenditure satisfies each
  19. 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…
  20. Treas. Reg. § 1.401(a)(4)-13(c)(6) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …ars of service after 1994 ((0.75 percent × $32,000 × 1 year) + (1.4 percent × $8,000 × 1 year), or $352); or(2) $3,872, the amended formula applied to Employee M's total years of service ((0.75 percent × $32,000 × 11 years) + (1.4 percent × $8,000 × 11 years)). Example 2.(a) Employer Y maintains a defined benefit plan,…