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21. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …helping to reduce costs for the self-insured group health plans and lower prescription drug prices.[279] By reducing prescription costs, the proposed rule could improve adherence to prescribed drugs, as patients are less likely to skip or reduce doses, delay refills, or forgo treatment due to financial concerns. Improv…
22. 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…
23. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
24. PLR 199922005 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.)
    IRCPrivate Letter RulingsJun 4, 1999
    … the close of its taxable year, was later declared obsolete under Revenue Ruling 84-50, 1984-1 C.B. 279. But see
25. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …. 6 8 .00% 286,000 36,54 2 1 286,000 25,000 261,000 21,880 282,88 0 2 282,880 25,000 257,880 21,630 279,51 0 3 279,510 25,000 254,510 21,361 275,87 1 4 275,871 25,000 250,871 21,070 271,94 1 5 271,941 25,000 246,941 20,755 267,69 6 6 267,696 25,000 242,696 20,416 263,11 2 7 263,112 25,000 238,112 20,049 258,16 1 8 258,…
26. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …hen their death benefits are used to satisfy their debts. See Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729 (1929); Sanders v. Commissioner, T.C. Memo. 2010-279, 2010 WL 5327897, at *2; McGowen v. Commissioner, T.C. Memo. 2009-285, 2009 WL 4797538, at *3-*5, aff'd, 438 Fed. Appx. 686 (10th Cir. 2011); Barr v.…
27. 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…
28. 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…
29. 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
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
30. 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…
31. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .
32. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …the respective years from 1990 through 1993, Lakewood paid Dr. Desai compensation of $318,020, $308,279, $297,452, and $275,270, it paid Dr. Sobo compensation of $330,030 $354,277, $329,185, and $203,640, it paid Dr. McManus compensation of $218,821, $368,708, $340,376, and $333,204, and it paid Dr. Sankhla compensatio…
33. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    … F.2d 727, 728– 29 (9th Cir. 1958), aff’g in part , remanding in part Funk v. Commissioner, 29 T.C. 279 (1957). Mr. Janangelo overstated deductions for each year at issue , and we have already found that respondent has clearly and convincingly demonstrated that an underpayment of tax exist s for each of those years . T…
34. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …nable cause defense is not available. See § 6664(c)(3); see also Chandler v. Commissioner, 142 T.C. 279, 293 (2014). B. Constitutional Challenge to Section 6662 Penalty Petitioner disputes the constitutionality of the accuracy-related penalty under section 6662 in the light of the U.S. Supreme Court’s decision in SEC v…
35. PLR 201351020 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsDec 20, 2013
    …the cash surrender value. The district court held in favor of taxpayer, citing Lucas v. Alexander , 279 U.S. 572 (1929), a case involving valuation of a life insurance policy where, in dicta, the court noted that ther e is an economic and presumably taxable gain when life insurance is surrendered or sold, calculated by…
36. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
37. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
38. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …,317 15,317 15,317 --- Rent/lease 21,135 21,135 21,135 --- Legal and professional 2,979 2,979 2,700 279 Interest 28,181 28,181 5,965 22,216 Insurance 17,070 17,070 12,351 4,719 Commissions and fees 125,952 125,952 125,952 --- Utilities 5,239 5,239 5,239 --- Office expenses 3,060 3,060 3,060 --- Depreciation/sec. 179 ex…
39. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
40. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    t "on account of" the earlier tax year in that the taxpayer had not proven that the "same treatment requirement" of Rev. Rul. 76-28 was satisfied. Id. (The only grace period contributions that we find to be "on account of" TYE 8801 and which, consequently, must be deducted in that year, are any delinquent payments and …