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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   ...................................................................... 111 Y. Regulations 118 .................................................... 114 Z. The Internal Revenue Code of 1954 ..................... 115 AA. The 1960 notice of proposed rulemaking ............. 119 BB. The creation of a new title of the Code o…
2. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
   IRCCourt RulingsAug 30, 1993related by meaning
   ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
4. 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…
5. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
   IRCCourt RulingsJan 9, 1985related by meaning
   erest) on the dates shown was as follows: Bate Balance 8/31/78 $123,727.08 8/31/79 131,211.18 8/31/80 141,708.07 8/31/81 144,502.33 4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
6. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
   IRCCourt RulingsMay 27, 1968related by meaning
   404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
7. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
   IRCCourt RulingsAug 26, 1968related by meaning
   ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
8. 58 T.C. 115 — Doing v. Commissioner
   IRCCourt RulingsApr 25, 1972related by meaning
   ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
9. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
   IRCCourt RulingsDec 16, 1998related by meaning
   rty within the 10-year period ending on the date of the transfer. (4) Amount involved.--The term "amount involved" means, with respect to a prohibited transaction, the greater of the amount of money and the fair market value of the other property given or the amount of money and the fair market value of the other prope…
10. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983related by meaning
    ennedy v. Commissioner, 72 T.C. 793, 805-806 (1979), revd. on other grounds 671 F.2d 167 (6th Cir. 1982); Kipnis v. Commissioner, T.C. Memo. 1982-471. Sec. 1348(b)(1)(A), as it stood for the years before 1979, imposed a mechanical 30-percent cap on self-employment income that could be treated as compensation if capital…
11. U.S. Tax Court — Vincent Marquez v. Commissioner
    IRCCourt RulingsMay 20, 2009related by meaning
    flimited by sec . 72(p)(2)(A) to one .- half of his retirement account balance . 1, applies,,in this case . Petitioner is subject to the section 72(t) additional tax . To ; reflect our disposition of the issues , Decision will be entere d it, for respondent . r
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. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
14. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    ) and (b) of section 4975. Section 4975 was added to the Internal Revenue Code by title II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions. The policy behind the enactment of section 4975 was to tax disqualified persons who engage in self-deal…
15. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976related by meaning
    loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
16. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    significance save that the words are strung together with syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited …
17. 57 T.C. 326 — Trebotich v. Commissioner
    IRCCourt RulingsDec 9, 1971related by meaning
    n will be entered under Rule 50. Drennen, /., dissents. All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
18. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
19. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    rectly involved in such ruling. * * *” See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
20. 49 T.C. 174 — Armanco Productions, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1967related by meaning
    dic or annual compensation on the basis of permanent employment; (c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…