Search the Pension Law Library

21. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974
    …, Mass. Mutual Life Ins. Co. v. United States, 288 U.S. 269, 274 (1933); Vern Realty, Inc., 58 T.C. 1005, 1011-1013 (1972), affirmed per order (C.A. 1, Apr. 26, 1973). Petitioners have not shown that BG timely paid the disputed funds to the trust.
22. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
23. DOL EBSA (final agency order) — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. NORTHWESTERN INSTITUTE OF PSYCHIATRY
    ERISACourt RulingsJul 26, 1995
    …67 S. Ct. 1559, 91 L. Ed. 2022 (1947)." Blake Construction Co., Inc. v. United States, 585 F2d 998, 1005 (Ct. Cl. 1978). NIP's CONTENTION THAT THE ALJ ERRED AS A MATTER OF LAW BY
24. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ddress the income tax consequences of the recharacterization of the DISC commissions. However, respondent's position that a transaction may be treated differently under different tax regimes seeds, on the surface, to have some support in 'cases which have held -that the income and gift tax statutes are not read in conj…
25. T.C. Memo. 2014-109 — Leslie J. Molinet Petitioner, and Michael F. Molinet, Intervenor v. Commissioner
    IRCCourt RulingsJun 9, 2014related by meaning
    t available to the spouse under section 6015(b) or (c). Sec. 6015(f)(1) and (2). Subsections (b) and (c) of section 6015 apply only in the case of "an understatement of tax" or "any deficiency" in tax, and do not apply in the case of underpayments of tax reported on joint tax returns. Sec. 6015(b)(1)(B), (c)(1); Hopkin…
26. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …bleness of the income and residual value projections. See also Helba v. Commissioner , 87 T.C. 983, 1005-1011 (1986), affd. without published opinion 860 F.2d 1075 (3d Cir. 1988). Levy concerned a sale and leaseback of computer equipment; the present case concerns the financial arrangements purporting to undergird an e…
27. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
28. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    stituting a 6-year period in lieu of the 3-year period otherwise referred to in such subsection. (D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market value, subparagraph (A) shall not apply. Section 313(…
29. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …ing Pharmacological Treatment for Opioid Dependence in California, 2006-2010, Addiction 110(6): 996-1005 (June 2015). Back to Citation 309.  Marc Larochelle, Dana Bernson, Thomas Land, Thomas Stopka, Na Wang, Ziming Xuan, Sarah Bagley, Jane Liebschutz, Alexander Walley, Medication for Opioid Use Disorder After Nonfatal…
30. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989
    …Petitioner’s argument implicates facts beyond those stipulated (cf. Hughes v. Commissioner, 42 T.C. 1005, 1012 (1964)), and respondent would be unfairly prejudiced by permitting the argument. Application of Section 1.415-6(b)(6), Income Tax Regs. Petitioners’ next argument is that respondent abused his discretion in no…
31. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
32. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
33. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
34. 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…
35. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998related by meaning
    of these funds since they were originally invested in the Fortis annuity contract in 1992. We conclude that petitioner's direct exchange of a portion of her Fortis annuity contract for a new Equitable annuity contract qualifies under section 1035 and that no gain to petitioner is to be recognized by reason of the exch…
36. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988
    … Workers Pension Fund v. New York State Teamsters Conference Pension and Retirement Fund, 80 A.D.2d 1005, 437 N.Y.S.2d 216 (1981), affd. 55 N.Y.2d 902, 449 N.Y.S.2d 24, 433 N.E.2d 1272 (1982). Again, on October 4, 1981, the Teamsters Fund moved for leave to renew its motion to vacate the 1975 order and judgment. The Ne…
37. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
38. 53 T.C. 385 — Loper Sheet Metal, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1969
    …laried employee, Mrs. Muriel Spark. Her employment as a secretary-receptionist commenced on May 10, 1005, and terminated on Feb. 3, 1907. She was paid total wages of $1,909.38 for May 10 to Oct. 31, 1965. No contributions to the profit-sharing plan were made on her behalf during the years ini issue. It follows from thi…
39. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    tions in his gross income for 1995. The only exception to section 408(d)(1) that might apply in the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The transfer of an individual's interest in an individual retirement account or an individual retirement annuity to his spo…
40. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    er husband and he was injured at the time of his early retirement, she should be taxed in the same manner as her former husband. A versiori of section 104(a)(1) allowing an injured person to exclude disability income from his or her taxable income has been in the Code since the Revenue Act of 1918 when it was added bec…