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91 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2002-166 — Wayne A. McFadden v. Commissioner
    IRCCourt RulingsJul 2, 2002
    …se debt, owed him by Stephanie and David on the Atascadero loan, was satisfied to the extent of $38,543, the amount by which the property’s fair market value--$207,500--exceeded the Great Western note secured by the first deed of trust--$168,957--and is a “cost” of the property to petitioner. In addition, petitioner to…
  2. 88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Feb 2, 2023
    …o Citation 29.   See Pennsylvania v. Trump, 281 F. Supp. 3d 553 (E.D. Pa. 2017), affirmed, 930 F.3d 543 (3d Cir. 2019). Back to Citation 30.   See Pennsylvania v. Trump, 351 F. Supp. 3d 791 (E.D. Pa. 2019), affirmed, 930 F.3d 543 (3d Cir. 2019); and California v. Azar, 351 F. Supp. 3d 1267 (N.D. Cal. 2019) (enjoining t…
  3. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …20,000 36,975,000 617,750 18,285,400 617,750 18,285,400 Uniform Glossary 1,102,000 1,102,000 18,367 543,653 18,367 543,653 Notice of Modification 1,160,000 719,200 11,987 354,805 11,987 354,805 Total 62,909,328 39,059,864 652,498 19,313,933 652,498 19,313,933 The Departments note that persons are not required to respon…
  4. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
  5. 77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Feb 3, 2012
    …tion 19,000 10,000 10,000 13,000 Notice to the Department 2,000 1,000 1,000 1,000 Total 9,513,000 1,543,000 1,543,000 4,200,000 Note: The displayed numbers are rounded to the nearest thousand and therefore may not add up to the totals These paperwork burden estimates are summarized as follows: Type of Review: Revision …
  6. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  7. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …xpense, the Court may estimate the amount.” Id. at *23 ( citing Cohan v. Commissioner, 39 F.2d 540, 543– 44 (2d Cir. 1930)). “In making the estimate, the Court bears heavily against the taxpayer who failed to more precisely substantiate the expense.” Id. ( citing Cohan v. Commissioner, 39 F.2d at 544). “The Court will …
  8. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  9. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ns reported the following information: 1988 1989 1990 1991 1992 Total income $440,673 $571,125 $672,543 $622,323 $639,859 Compensation of officers 164,000 327,000 450,000 315,000 367,000 Salaries & wages 86,551 36,600 42,656 23,247-0 - Pension, profit-sharing, plans 73,462 77,769 93,556 160,351 102,506 Employee benefit…
  10. T.C. Summary Opinion 2004-29 — Howard T. Owens, Jr. & Ann E. Owens v. Commissioner
    IRCCourt RulingsMar 15, 2004related by meaning
    t 22, 2001, respondent issued to petitioners a notice of deficiency determining that they were liable for this additional tax in the amount of $2,000. Discussion I. General Rules In general, section 408 governs the treatment of IRAs. Specifically, section 408(d) provides that distributions from an IRA are taxable in th…
  11. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
  12. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996
    …on of the Court of Appeals for the Ninth Circuit in Albertson's Inc. v. Commissioner , 42 F.3d 537, 543 (9th Cir. 1994), affg. 95 T.C. 415 (1990). The Ninth Circuit noted that, for nonqualified plans, "the employer is ordinarily allowed no deduction for contribution, payments or benefits until they are taxed to the emp…
  13. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …,018 205,143 75,875 147,540 Total Small Private 769,646 561,842 207,805 404,080 All Small Plans 827,543 604,107 223,437 434,477 * Totals displayed in the table may not sum due to rounding. 3. Cost of Proposed Rules a. Small Plan Sponsors and Plans Small plan sponsors would be able to choose to offer excepted fertility …
  14. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959related by meaning
    s for such determination. Such statement shall not be used in the Tax Court of the United States as proof of the facts or conclusions stated' therein. “This subsection shall be applicable to all contracts and subcontracts, to the extent of the amounts received or accrued thereunder in any fiscal year ending after June …
  15. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …ckett, 584 U.S. at 441–42 (citation omitted); Ro s setto v. Pabst Brewing Co., Inc. , 217 F.3d 539, 543 (7th Cir. 2000) (noting presumption that employee’s entitlement to retiree healthcare benefits expires with termination of CBA) (citing Bidlack v. Wheelabrator Corp. , 993 F.2d 603, 606 (7th Cir. 1993) (en banc)). At …
  16. 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…
  17. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
  18. 29 T.C. 22 — Loeb v. Commissioner
    IRCCourt RulingsOct 11, 1957
    …ance Company for insurance on the life of Clarence. On that day, Home Life issued policy number 484,543 in the face amount of $10,000 on the life of Clarence. This policy is hereinafter referred to as the Home Life policy. Bessie was the primary beneficiary of this policy and the policy provided specifically that Bessi…
  19. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962related by meaning
    ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated. Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act. Thls section was originally desi…
  20. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…