Search the Pension Law Library

1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
   IRCCourt RulingsMar 5, 2018related by meaning
   Roth IRAs Were Exposed to No Risk.. . . . . . . . . . . . . . . . . 43 B. The Roth IRAs Could Expect No Upside Benefits . . . . . . . . . . . 47 -4 - C. Conclusion .......................................... 49 VII. Petitioners' Counterarguments .............................. 51 A. Summa Holdings II ...................…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …erpret, or prescribe law or policy”. Section 2(c) of the APA (codifi ed as amended at 5 U.S.C. sec. 551(4) (2018) ) . Section 4 of the APA 85 dealt with “rule making” by agencies. “Rule making” was defined as “agency process for the formulation, amendment, or repeal of a rule”. Section 2(c) of the APA (codified as amen…
3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
4. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
   IRCCourt RulingsFeb 22, 1989★ strong match
   …ons of the Internal Revenue Code of 1954 as in effect for the year in issue. As of 1981, La.R.S. 42:551 and 553 provided for membership in LASER & Co. as follows: Sec. 551. Eligibility for membership The membership of this system shall be composed as follows: (1) Each person who becomes an employee in the state service…
5. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
   IRCCourt RulingsDec 29, 2005related by meaning
   d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
6. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
   IRCCourt RulingsJul 31, 2000
   …he Lakewood Plan a second Sygnet 24 group annuity (#D11794/D90214). The Lakewood Plan deposited $75,551.50 into the annuity on the day it was effective and closed the annuity on November 25, 1996, withdrawing $65,078.20. The Lakewood Plan paid a $15,865.68 charge on its deposit and a $3,436.85 surrender charge on its
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. 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…
9. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
   IRCCourt RulingsNov 17, 2005
   …cs. 2031(a), 2033; sec. 20.2031-1.(b), Estate Tax Regs.; United States v. Cartwright, 411 U.S. 546, 551 (1973). Fair market value reflects the price that the property would "change hands between a willing buyer and a willing .seller, neither being under any compulsion to buy or to sell and both having reasonable knowle…
10. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
11. 75 FR 51623 — Registration of Mortgage Loan Originators
    IRCFinal Rules (FR)Aug 23, 2010
    …eporting requirement is triggered in instances where NCUA issues a final rule as defined by section 551 of the Administrative Procedure Act. 5 U.S.C. 551. NCUA does not believe this final rule is a “major rule” within the meaning of the relevant sections of SBREFA. NCUA has submitted the rule to the Office of Managemen…
12. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
13. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    ….2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228; Crowley v. Commissioner , T.C. Memo. 1995-551, affd. without published opinion sub nom. Cockrell v. Commissioner
14. 75 FR 44656 — Registration of Mortgage Loan Originators
    IRCFinal Rules (FR)Jul 28, 2010
    …eporting requirement is triggered in instances where NCUA issues a final rule as defined by section 551 of the Administrative Procedure Act. 5 U.S.C. 551. NCUA does not believe this final rule is a “major rule” within the meaning of the relevant sections of SBREFA. NCUA has submitted the rule to the Office of Managemen…
15. 83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Nov 15, 2018
    …notices will be sent electronically, and 46.3 percent will be mailed.[120] Therefore, approximately 551,254 notices will be mailed. HHS estimates that each notice will require $0.50 in postage and $0.05 in materials cost (paper and ink) and the total postage and materials cost for each notice sent via mail will be $0.5…
16. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
17. 76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes
    IRCFinal Rules (FR)Jun 24, 2011
    … rule authority applies to these amendments. Under the Administrative Procedure Act (APA) (5 U.S.C. 551
18. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    …018 is discounted for 12 1/2 months at the effective interest rate ($25,000 ÷ 1.0590(12.5/12) = $23,551).(E) The sum of the above contributions for the 2017 plan year paid through January 15, 2018, adjusted for interest to the valuation date, is $96,263.
19. 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’ …
20. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995★ strong match
    …0 Expense of sale 9,514.04 Amount realized 100,485.96 Basis of home sold 107,037.40 Gain on sale (6,551.44) In response to the query "If you haven't replaced your home, do you plan to do so within the replacement period?" petitioners answered in the affirmative. In the notice of deficiency, respondent determined that p…