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21. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015
    …profit. Dreicer v. Commissioner, 78 T.C. 642, 643 (1982), aff'd without published opinion, 702 F.2d 1205 (D.C. Cir. 1983). The taxpayer's expectation of profit need not be a reasonable one, but merely bona fide. Id ; sec. 1.183-2(a), Income Tax Regs. Whether a taxpayer expects to realize a profit is a question of fact …
22. 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.
23. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    ….C. Memo. 1964-2; Dreicer v. Commissioner , 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983); Jasionowski v. Commissioner , 66 T.C. 312, 319 (1976); sec. 1.183-2(a), Income Tax Regs. Although a taxpayer’s expectation of profit need not be reasonable, there must be a good faith objective of …
24. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
25. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
26. 44 T.C. 178 — Funkhouser v. Commissioner
    IRCCourt RulingsMay 13, 1965
    …” such separation. The burden of proof was upon petitioner, cf. Estate of Edward I. Rieben, 32 T.C. 1205, 1208; Welch v. Helvering, 290 U.S. 111, 115, and the record shows merely that petitioner at sometime between April 10 and June 4,1959, “requested” the trustee to surrender one of his policies for cash, and that he …
27. PLR 200005001 — Tax on Reversion of Qualified Plan Assets to Employer
    IRCPrivate Letter RulingsFeb 4, 2000
    …auserman, Inc. , 126 F.3d 811 (6th Cir. 1997) (same); PBGC v. Skeen (In re: Bayly Corp.) , 163 F.3d 1205 (10th Cir. 1998) (PBGC claim for unfunded benefit liabilities); In re Unitcast , 219 BR 741 (6th Cir. BAP 1998) (IRC §4971 penalties). These cases are distinguishable because they involve debts arising from obligati…
28. 29 C.F.R. § 4000.28 — [Reserved]
    PBGCRegulationsDec 7, 2023related by meaning
    [Reserved]
29. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
30. T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations …
    IRCTreasury DecisionsAug 6, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-50 Rev. Rul. 2007-50 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2007. T.D. 9329 T.D. 9329 Final regulations under sect…
31. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985
    …his employer. Bolden v. Commissioner, 39 T.C. 829 (1963); Estate of Rieben v. Commissioner, 32 T.C. 1205 (1959); Oliphint v. Commissioner, 24 T.C. 744 (1955), affd. on another point 234 F.2d 699 (5th Cir. 1956); Estate of Fry v. Commissioner, 19 T.C. 461 (1952), affd. per curiam 205 F.2d 517 (3d Cir. 1953); Glinske v. …
32. 29 C.F.R. § 4907.171-4907.999 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
33. 29 C.F.R. § 4907.152-4907.159 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
34. 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…
35. 29 C.F.R. § 4281.14-4281.15 — [Reserved]
    PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
36. 29 C.F.R. § 4907.104-4907.109 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
37. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
38. 29 C.F.R. § 2570.61 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
39. 29 C.F.R. § 2570.113 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
40. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]