ERISACourt RulingsAug 10, 2026
… would take only a day or two
following the settlement period for the sale of Altria stock . ” J.A. 744. But the management
USCA4 Appeal: 25-1350 Doc: 89 Filed: 08/10/2026 Pg: 11 of 21
12
committee determined that Kelly was later told “that the cash rollover to the Fidelity IRA
would take approximately three to five bu…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
ERISACourt RulingsAug 10, 2026
… would take only a day or two
following the settlement period for the sale of Altria stock . ” J.A. 744. But the management
USCA4 Appeal: 25-2080 Doc: 59 Filed: 08/10/2026 Pg: 11 of 21
12
committee determined that Kelly was later told “that the cash rollover to the Fidelity IRA
would take approximately three to five bu…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsSep 18, 2018
…vestment gains thereon, the
"accumulation value" of the Policy was $640,358 at the end of 2011 and $744,460
at the end of 2012, according to the quarterly statements issued by AGLI.
If an employer participating in the Flex Plan made all required contributions
before December 1, 2011, and thereafter terminated participa…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.3 of this title.
IRCCourt RulingsJun 13, 2017
…endar year. At year-end 2009 and 2010 Petersen had accrued but unpaid vacation pay expenses of $473,744 and $503,896, respectively. These amounts were
paid to its employees by December 31 of the following year. Roughly 94.5% of
these amounts was attributable to employees who participated in the ESOP.3
Petersen filed ti…
IRCCourt RulingsOct 16, 2001related by meaning
hin the taxable year
in carrying on a trade or business or an activity described
in section 212 (relating to expenses for production of
income). * * * Section 164(a) does not mention Federal income taxes. On
the other hand, section 275(a)(1) provides, inter alia, that no
deduction shall be allowed for Federal income ta…
IRCCourt RulingsJul 2, 2002
…e in Dallas, Texas, which she sold in 1996 for a gain of $45,401. Stephanie earned $87,148
and $100,744 in 1995 and 1996, respectively.
On his 1995 Federal income tax return, petitioner reported
the $170,371 early distribution in gross income and calculated a
tax of $17,037 for an early distribution under section 72(t)…
IRCCourt RulingsDec 19, 2000★ strong match
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 …
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…22,679,988 16,144,825 19,283,596 18,786,948
P. Deductible limit
7
8,009,729 8,705,163 10,828,045 12,744,581
1
C.c - D
2
B.c - E
3
F/G
4
A x (C.a - D + H + ½ of (J - I))
5
C.a - D + H - I + J + K
6
Smaller of (N - L) and (D + M), but not below zero
7
D + M - O
- 30 -
Mr. Daskais opined that, if the funding method used t…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
IRCCourt RulingsJun 17, 1997
…), docket No. 5754-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1)
6662(a)
1989 $12,744 $637 $2,549
Howard S. Young & Elaine P. Young (the Youngs),
docket No. 5755-94
Addition to Tax
Penalty
Sec. Sec.
Year
Deficiency
6651(a)(1)
6662(a)
1989 $14,008 --- $2,802
Bruce E. Traegde & Patricia Traegde (the Tra…
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…
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 …
IRCCourt RulingsApr 3, 2018
…tions and made $123,664 in after-tax contributions
comprising $17,920 for "Public Service" and $105,744 for ARSC. He made no
other after-tax contributions to CalPERS.
- 3 -
During 2014 petitioner received retirement distributions from CalPERS of
$31,973. For 2014 CalPERS reported to the Internal Revenue Service (IRS) t…
88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
tax-favored under the same country's laws) must be made in cash and must be based on income earned from employment or self-employment activities.
See sections 219, 408, and 408A. Third, in appropriate fact patterns, the transaction viewed as a whole may be disregarded under relevant judicial doctrines, including the s…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999★ strong match
…alified person
under section 4975(e)(2)(H).
In Framingham Union Hosp., Inc. v. Travelers Ins. Co.
, 744
F. Supp. 29, 31-32 (D. Mass. 1990), the Secretary of Labor
alleged that petitioner and the Garrahan Agency knowingly
participated in prohibited transactions and other breaches of
fiduciary duty. The complaint was dis…
IRCCourt RulingsAug 1, 2012
…e working as an assistant professor
at the University of Rhode Island. During 2007 she received $18,744 from this
IRA. She also received $67,000 that year from a Pennsylvania M Fund account,
another IRA held in her name.
- 3 -
[*3] During 2007 petitioners received income from interest, royalties, dividends,
Social Secu…