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90 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  2. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …244 .07 Advisory letters on § 403(b) VS plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28 245 .08 Determination letters 245 .09 User fees for VCP submissions under EPCRS Revenue Procedure 2021-30 245 APPENDIX B1 SAMPLE NOTICE TO INTERESTED PARTIES (QUALIFIED PLANS) 247 APPENDIX B2 SAMPLE NOTICE TO INTERESTED …
  3. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  4. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …ge 39. The first-year premium was $5,750, and the cost of insuring Dr. Sankhla for that year was $1,245.51. Lakewood paid this premium, and, at the end of that year, the conversion credit balance was $4,707.19 ($5,750 - $1,245.51 + $202.70); the $202.70 is the interest of 4.5 percent earned on the conversion credit bal…
  6. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  7. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  8. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    lating to petitioners' loan, 10.5 percent is the fair market interest rate. V. Addition to Tax Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to file Form 5330 for each taxable year, or portion thereof, in the taxable period. Sec. 6011; sec. 54.6011-1(…
  9. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    n. The Commissioner determined that the individual petitioners were hable for excise taxes under section 4975(a) for each such prohibited transaction. The Commissioner also sent a notice of deficiency to MMR, in which he determined that the lease of the property to MMR by the plan was a prohibited transaction. In such …
  10. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013
    …s due to reasonable cause and not due to willful neglect. See United States v. Boyle, 469 U.S. 241, 245 (1985); United States v. Nordbrock, 38 F.3d 440, 444 (9th Cir. 1994). Failure to timely file a Federal income tax return is due to reasonable cause if the taxpayer exercised ordinary business care and prudence but ne…
  11. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  12. T.C. Memo. 2004-287 — Michael J. Barkley v. Commissioner
    IRCCourt RulingsDec 28, 2004
    …e cause and not due to willful neglect. See sec. 6651(a)(1); United States v. Boyle , 469 U.S. 241, 245 (1985); United States v. Nordbrock , 38 F.3d 440, 444 (9th Cir. 1994); Harris v. Commissioner , T.C. Memo. 1998-332. A failure to file a timely Federal income tax return is due to reasonable cause if the taxpayer exe…
  13. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…
  14. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026
    …tax issue or issues the whistleblower’s information identifies.” Lissack v. Commissioner, 125 F.4th 245, 25 7 (D.C. Cir. 2025), aff’g 157 T.C. 6 3 (2021).
  15. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    …from willful neglect and (2) was due to reasonable cause. See United States v. Boyle, 469 U.S. 241, 245-246 (1985); Crocker v. Commissioner, 92 T.C. 899, 912-913 (1989); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect has been defined as a "conscious, intentional failure or reckless indifference." Boyle, …
  16. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  17. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  18. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    …r or Incorporation and the Status of the Agreement in Relation to the Decree, 67 Neb. L. Rev . 235, 245 (1988). As a result, the terms of an agreement merged into a divorc e decree generally may be enforced through contempt proceedings (and modified by the court), but do not provide the parties with a cause of action b…
  19. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  20. T.C. Summary Opinion 2005-80 — Harald Berrey v. Commissioner
    IRCCourt RulingsJun 9, 2005
    …he failure to file and/or pay was “due to reasonable cause”. United States v. Boyle , 469 U.S. 241, 245 (1985); Heman v. Commissioner , 32 T.C. 479, 489-490 (1959), affd. 283 F.2d 227 (8th Cir. 1960). If petitioner exercised ordinary business care and prudence and was nonetheless unable to file his return or pay - 11 -…