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58 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  2. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    … and Money Savings from a VA National Telehealth Tablet Initiative, 26(8) Telemedicine and e-Health 1178-1183 (2020); Navjit W. Dullet, Estella M. Geraghty, Taylor Kaufman, Jamie L. Kissee, Jesse King, Madan Dharmar, Anthony C. Smith, & James P. Marci, Impact of a University-Based Outpatient Telemedicine Program on Tim…
  3. 81 FR 7253 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014
    IRCProposed Rules (FR)Proposed Feb 11, 2016
    …der that language superfluous in subclause (I), see Marx v. General Revenue Corp., 133 S. Ct. 1166, 1178 (2013) (“[T]he canon against surplusage is strongest when an interpretation would render superfluous another part of the same statutory scheme.”), or effectively rewrite subclause (II) to include that requirement, s…
  4. 81 FR 27011 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014
    IRCFinal Rules (FR)May 5, 2016
    …t issue here. Back to Citation 5.   See Marx v. General Revenue Corp., 568 U.S.__, 133 S. Ct. 1166, 1178 (2013) (“[T]he canon against surplusage is strongest when an interpretation would render superfluous another part of the same statutory scheme.”). Back to Citation 6.  The preamble to the proposed regulations reques…
  5. 80 FR 71936 — Interpretive Bulletin Relating to State Savings Programs That Sponsor or Facilitate Plans Covered by the Employee Retirement Income Security Act of 1974
    ERISAFinal Rules (FR)Nov 18, 2015
    …ated General Contractors of America v. Metropolitan Water District of Southern California, 159 F.3d 1178, 1182-84 (9th Cir. 1998) (recognizing a similar distinction between state regulation and state market participation). By merely offering employers particular ERISA-covered plan options [15] (or non-ERISA plan option…
  6. 64 T.C. 621 — Richardson v. Commissioner
    IRCCourt RulingsJul 23, 1975
    …ed 364 U.S. 908 (1960); Goodstein v. Commissioner, 267 F.2d 127, 132 (1st Cir. 1959), affg. 30 T.C. 1178 (1958); Shakespeare Co. v. United States, 182 Ct. Cl. 119, 128, 389 F.2d 772, 777 (1968); Knetsch v. United States, 172 Ct. Cl. 378, 391, 348 F.2d 932, 940 (1965), cert. denied 383 U.S. 957 (1966); Bornstein v. Unit…
  7. T.C. Summary Opinion 2006-170 — Nader Ghazitehrani and Farzaneh Zamanizadeh v. Commissioner
    IRCCourt RulingsOct 23, 2006related by meaning
    T .C . Summary Opinion 2006-17 0 UNITED STATES TAX COUR T NADER GHAZITEHRANI AND FARZANEH ZAMANIZADEH, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 12653-05S . Filed October 23, 2006 . Nader Ghazitehrani and Farzaneh Zamanizadeh, pro sese . Aimee R . Lobo-Berg , Thomas J . Travers , and Ann…
  8. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  9. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
  10. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016
    …the subclauses at issue here. [5] See Marx v. General Revenue Corp., 568 U.S. ___, 133 S. Ct. 1166, 1178 (2013) (“[T]he canon against surplusage is strongest when an interpretation would render superfluous another part of the same statutory scheme.”). [6] The preamble to the proposed regulations requested comments on a…
  11. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    tiation rules. Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary Income Tax Regs., supra. These strict substantiation rules generally require the taxpayer to substantiate with adequate records or by sufficient evidence corroborating the taxpayer…
  12. Ann. 2011-79 — This announcement describes rules that the Treasury Department and the IRS are considering proposing relating to the determination of whether a plan of an Indi…
    IRCAnnouncementsDec 19, 2011
    … than sections 403(b)(1)(A)(ii)). [49] See Dobbs v. Anthem Blue Cross & Blue Shield, 475 F.3d 1176, 1178 (10th Cir. 2007) (citing 150 Cong. Rec. S9526, 9533), rev’d in part 600 F.3d 1275 (2010). See also Bolssen v. Unum Life Insurance Company of America, 629 F.Supp. 2d 878, 881 (E.D. Wis. 2009). [50] San Manuel Indian …
  13. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    ax of $3,000.60 because she received.the distributions before she attained age 59-1/2 and the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v). Discussion Summary judgment is intended to.expedite litigation and avoid unnecessary and expensive trials and may be granted where the…
  14. 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…
  15. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  16. PLR 200548031 — Additional Tax
    IRCPrivate Letter RulingsDec 2, 2005related by meaning
    - - - - -
  17. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM November 21, 2005 Third Party Communication: None Date of Communication: Not Applicable Number: 200610016 Release Date: 3/10/2006 Index (UIL) No.: 832.09-00, 404.11-00, 446.04-00 CASE-MIS No.: TAM- 134113-05/CC:FIP:B4 --------------------------------…
  18. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
  19. 64 T.C. 901 — Precision Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 19, 1975related by meaning
    al $100 contribution. This would have occurred after March 10,1970, but we do not know if it was prior to the end of the fiscal year on March 31,1970. Petitioner argues that these oral representations to the employees coupled with the informal agreement by the directors to adopt the plan clearly establish that Precisio…
  20. 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 …