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21. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
22. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
23. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    ven report the distributions. the clear intent of Congress to prevent voluntary withdrawals, we decided that the penalty was inapplicable. Id. at 291. Petitioners’ reliance on Larotonda v. Commissioner , supra , is misplaced. Here, respondent did not levy on the retirement accounts. Petitioners made voluntary withdrawa…
24. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
25. 29 C.F.R. § 4907.171-4907.999 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
26. T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec…
    IRCTreasury DecisionsAug 12, 2024related by meaning
    regulations were first issued in 1995. Many rules in existing final regulations are restated without change to satisfy Federal Register requirements. 26 CFR 1.401(a)(9)-0 through 26 CFR 1.401(a)(9)-9; 26 CFR 1.402(c)-2; 26 CFR 1.403(b)-6; 26 CFR 1.457-6; 26 CFR 1.408-8; 26 CFR 54.4974-1 INCOME TAX REG-102161-23, page …
27. 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…
28. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
29. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    now how these deductions were calculated. She did not substantiate such expenses. Therefore, this Court holds that such deductions are not allowed and respondent’s disallowance of such deductions is sustained. Due to our holding that petitioner has not substantiated any of the claimed Schedule C deductions for Port of …
30. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005related by meaning
    . 213 shall be deemed paid for by a portion of petitioner’s withdrawal from his thrift savings plan and are therefore excepted from the additional tax under sec. 72(t). Respondent further concedes that petitioner’s filing status is married filing jointly. Respondent determined a deficiency in petitioner’s Federal incom…
31. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
32. 58 T.C. 940 — Funkhouser v. Commissioner
    IRCCourt RulingsSep 11, 1972related by meaning
    tation of that section. Petitioners contend that Eev. Eul. 69-544 is at variance with the plain wording of section 1.72-16 (b) (6) of the regulations. In Raymond J. Moore, 45 B.T.A. 1073 (1941), we held that the portion of the premiums paid by a qualified pension trust for the benefit of employees for an annuity contra…
33. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
34. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ons of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. - 3 - After concessions, the following 2 issues remain for us to resolve in the present proceeding: (1) Whether petitioner, in its taxable year ending January 30, 1988 (TYE 88…
35. 79 FR 51118 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Aug 27, 2014related by meaning
    sions Reporting and recordkeeping requirements 29 CFR Part 2590 Continuation coverage Disclosure Employee benefit plans Group health plans Health care Health insurance Medical child support Reporting and recordkeeping requirements 45 CFR Part 147 Health care Health insurance Reporting and recordkeeping requirements Sta…
36. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
37. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961related by meaning
    e distribution. Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
38. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
39. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
40. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978related by meaning
    ioner for the purpose of computing its depreciation deductions. FINDINGS OF FACT Some of the facts have been stipulated, and those facts are so found. The petitioner in docket No. 8683-74 is 212 Corporation (212 Corp.), which had its principal place of business in Erie, Pa., at the time it filed its petition in this ca…