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1. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
   IRCCourt RulingsFeb 22, 1989related by meaning
   n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
2. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
   IRCProposed Rules (FR)Proposed Sep 16, 2021
   …ions of these proposed rules that apply to plans and issuers, proposed to be codified at 45 CFR 149.460, would apply to grandfathered plans. The Departments seek comment on the use of the calendar year as the reporting period, including the time it typically takes to fully adjudicate and pay claims for air ambulance se…
3. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
   IRCCourt RulingsDec 18, 2012★ strong match
   … follows: - 13 - [*13] Year Bank Account Deposited Rent 1992 FFB3886 $21.113 21,113 1993 FFB3886 11,460 11,460 1994 CB9250 12,553 FFB3886 875 13,428 1995 BOA3721 875 BOA3886 9,545 CB9250 1,500 FFB1604 5,988 17,908
4. PLR 201833014 — Treatment of Funded Welfare Benefit Plans
   IRCPrivate Letter RulingsAug 17, 2018
   …h the premise on which the deduction was initially based. Hillsboro National Bank v. Commissioner , 460 U.S. 370 (1983); see also Hughes & Luce, LLP v. Commissioner , 70 F.3d 16 (5 t h Cir. 1995), cert. denied , 517 U.S. 1208 (1996). The term “tax benefit rule” encompasses two concepts, an inclusionary part and an excl…
5. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   8 years on June 10, 2016. That notice was issued timely because, as of 3 The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
6. Treas. Reg. § 1.101-4(g) — Payment of life insurance proceeds at a date later than death.
   IRCRegulationsJan 19, 2017
   expectancy ($61,500 divided by 25, or $2,460). Hence, $2,460 of each $4,000 payment is excludable from A's gross income. If A is the surviving spouse of the insured and no other contracts of insurance whose proceeds are to be paid to her at a date later than death are involved, A shall exclude $3,460 of each $4,000 pay…
7. 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. …
8. PLR 201117013 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
   IRCPrivate Letter RulingsApr 29, 2011
   … premi se on which the deduction was initially based. See Hillsboro National Bank v. Commissioner , 460 U.S. 370, 377 (1983). The tax benefit rule will “cancel out” an earlier deduction when the later event is fundamentally inconsistent with the premise on which the deduction was initially based, even if there is no ac…
9. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
   IRCCourt RulingsSep 24, 2026
   …s we re as follows: Distributions from E*Trade IRA Amount Cash transfers to Wells Fargo account $37,460 Cash transfers to E*Trade brokerage account 120,013 Stock t ransfers to E*Trade brokerage account 72,3 84 TOTAL $229,857 4 3 The IRS may not rely solely on a third-party report of income, such as a Form 1099, if the …
10. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    vant facts." Lawinger v. Commissioner, 103 T.C. 428, 440 n.8 (1994). - 24 - [*24] Substantial authority exists only when the weight of the authorities supporting the treatment of the tax item is substantial in relation to the weight of the authorities supporting contrary treatment. Sec. 1.6662-4(d)(3)(i), Income Tax Re…
11. 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…
12. 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…
13. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
14. PLR 201825012 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsJun 22, 2018
    …h the premise on which the deduction was initially based. Hillsboro National Bank v. Commissioner , 460 U.S. 370 (1983); see also Hughes & Luce, LLP v. Commissioner , 70 F.3d 16 (5 th Cir. 1995), cert. denied , 517 U.S. 1208 PLR - 130292-17 4 (1996). The term “tax benefit rule” encompasses two concepts, an inclusionary…
15. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
16. PLR 201442065 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsOct 17, 2014
    …th the premise on which the deduction was initially based. Hillsboro National Bank v. Commissioner, 460 U.S. 370 (1983); see also Hughes & Luce. LLP v. Commissioner, 70 F.3d 16 (5th Cir. 1995), cert. denied, 517 U.S. 1208 (1996). The term "tax benefit rule" encompasses two concepts, an inclusionary part and an exclusio…
17. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
18. T.C. Summary Opinion 2006-11 — Richard Bradley v. Commissioner
    IRCCourt RulingsJan 26, 2006
    …bution to petitioner from an Eaglesponsored retirement plan. Petitioner received a net amount of $5,460. At trial, petitioner testified that he could not remember receiving a distribution from ING or depositing a check dated October 26, 2001, for $5,460 into his bank account. Respondent, however, received an informatio…
19. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
20. PLR 201442064 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsOct 17, 2014
    …th the premise on which the deduction was initially based. Hillsboro National Bank v. Commissioner, 460 U.S. 370 (1983); see also Hughes & Luce, LLP v. Commissioner, 70 F.3d 16 (5th Cir. 1995), cert. denied, 517 U.S. 1208 (1996). The term "tax benefit rule"