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21. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
22. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015related by meaning
    report the initial retirement distribution of $4,984 from State Street; that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of the retirement distribution includible in gross income; and that he was liable for an a…
23. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
24. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …nd the health benefit plan. Back to Citation 86.  18 U.S.C. 1836(b). Back to Citation 87.  5 U.S.C. 552. Back to Citation 88.  18 U.S.C. 1839(5)-(6). Back to Citation 89.  5 U.S.C. 552. Back to Citation 90.  5 U.S.C. 552(b)(4). Back to Citation 91.  42 U.S.C. 1320b-23(c). Back to Citation 92.  42 U.S.C. 300gg(18)(e). B…
25. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
26. 20 C.F.R. § 902.4(a) — Access to records.
    Joint BoardRegulationsOct 18, 2016
    (a) (a) General rule. All records of the Joint Board, including information set forth in section 552(a)(2) of title 5 of the United States Code, are made available to any person, upon request, for inspection and copying in accordance with the provisions of this section and subject to the limitations stated in section 5…
27. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
28. Treas. Reg. § 1.401(a)(4)-13(c)(6) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …nd has covered compensation of $32,000. Employee M's accrued benefit as of December 31, 1995, is $4,552, the greater of—(1) $4,552, the sum of Employee M's accrued benefit frozen as of December 31, 1994, ($4,200) and the amended formula applied to Employee M's years of service after 1994 ((0.75 percent × $32,000 × 1 ye…
29. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
30. 29 C.F.R. § 4901.2 — Definitions.
    PBGCRegulationsAug 24, 2022
    … any independent regulatory agency. FOIA means the Freedom of Information Act, as amended (5 U.S.C. 552). Record has the meaning attributed to it by section 552(f)(2) of FOIA. Working day means any weekday excepting Federal holidays.
31. U.S. Tax Court — Vincent Marquez v. Commissioner
    IRCCourt RulingsMay 20, 2009related by meaning
    flimited by sec . 72(p)(2)(A) to one .- half of his retirement account balance . 1, applies,,in this case . Petitioner is subject to the section 72(t) additional tax . To ; reflect our disposition of the issues , Decision will be entere d it, for respondent . r
32. 29 C.F.R. § 4901.4(d)(4) — Information maintained in electronic reading room.
    PBGCRegulationsAug 24, 2022
    (d)(4) (4) Frequently requested records. Records that have been released under section 552(a)(3) of FOIA and have been the subject of three or more disclosure requests; and (d)(5) (5) Other records. Records that have been released under section 552(a)(3) of FOIA and that PBGC determines, because of the nature of the re…
33. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
34. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    …rivate foundations. See H. Rept. 91-413 (Part 1), 4, 20-21 (1969), 1969-3 C.B 202, 214; S. Rept. 91-552, 6, 28-29 (1969), 1969-3 C.B. 426, 442-443; also see Staff of the Joint Committee on Internal Revenue Taxation, General Explanation of the Tax Reform Act of 1969 (hereinafter sometimes referred to as the TRA '69 Blue…
35. 29 C.F.R. § 4901.24(d) — Special rules for trade secrets and confidential commercial or financial information submitted to PBGC.
    PBGCRegulationsAug 24, 2022
    … all grounds relied upon for opposing disclosure of any portion(s) of the information under section 552(b) of FOIA and, with respect to the exemption in section 552(b)(4), demonstrate why the information is a trade secret or is commercial or financial information that is privileged or confidential. Facts asserted must …
36. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    8 years on June 10, 2016. That notice was issued timely because, as of 3 The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
37. T.C. Summary Opinion 2014-84 — David C. Matthews & Marcia K. Matthews v. Commissioner
    IRCCourt RulingsAug 28, 2014related by meaning
    lan before attaining the age of 59-1/2, section 72(t) imposes an additional tax equal to 10% of the portion of the distribution which is includible in the taxpayer's gross income.3 Sec. 72(t)(1) and (2). The additional tax is intended to discourage taxpayers from taking premature distributions from retirement plans--ac…
38. 29 C.F.R. § 4902.11(b) — Specific exemptions: Office of Inspector General Investigative File System.
    PBGCRegulationsJan 6, 2025
    (b) (b) Other Law Enforcement (b)(1) (1) Exemption. Under the authority granted by 5 U.S.C. 552a(k)(2), PBGC hereby exempts the system of records entitled “PBGC-17, Office of Inspector General Investigative File System” from the provisions of 5 U.S.C. 552a(c)(3), (d)(1) through (4), (e)(1), (e)(4)(G) and (H), and (f) f…
39. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
40. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    mewhat similar to those of the FSC regime), and the DISC made payments to the Roth IRAs, which the taxpayers claimed were dividend income to the IRAs. Holding for the Commissioner, we concluded that in substance the payments to the Roth IRAs were contributions and not income from the DISC. The taxpayers before this Cou…