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86 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  2. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …aspects of the business. On the basis of petitioner husband's credible testimony, we find that the $320,000 purchase price was wholly allocable to the insurance firm's workforce in place, information base, and goodwill, all of which are amortizable section 197 intangibles.¹² See sec. 197(c) and (d). However, the amorti…
  3. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …arrive at the gain realized on the California property. In particular, he calculated a total of $35,320 in depreciation as follows: 17 Year Amount of Depreciation 1985 $2,906 1986 13,374 1987 12,225 1988 6,364 1989 451 Total 35,320 Such figures would seem to indicate that petitioners did, in fact, rent out the Californ…
  4. T.C. Memo. 2017-142 — Block Developers, LLC, William J. Maxam, APC, Tax Matters Partner v. Commissioner
    IRCCourt RulingsJul 18, 2017related by meaning
    free, and qualified distributions down the line are not included in a taxpayer's gross income. Sec. 408A(c)(1), (d)(1); Taproot Admin. Servs., Inc. v. ¹6 We were, however, a bit ambiguous. In the introduction to our analysis we described the Commissioner's argument that his agent was "required" to mail notice to the in…
  5. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012
    …n expenditure is ordinary and necessary is generally a question of fact. Commissioner v: Heiningerg 320 U.S. 467, 475.(1943). Ah expense is ordinary if it is customary or usual within a particular trade, business, or industry or relates to a transaction "of - -33_ common or frequent occurrence in the type of business i…
  6. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  7. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …e is one that commonly or frequently occurs in the taxpayer’s business); Commissioner v. Heininger, 320 U.S. 467, 471 (1943) (explaining that a necessary expense is one that is appropriate and helpful in carrying on the taxpayer’s business) ; Treas. Reg. § 1.1621(a) . Generally, the performance of services as an employ…
  8. 46 T.C. 431 — John C. Nordt Co. v. Commissioner
    IRCCourt RulingsJun 24, 1966
    …), I.R.C. 1954; Lucas v. Ox Fibre Brush Co., 281 U.S. 115 (1930); General Smelting Co., 4 T.C. 313, 320; Associated Theatres Corporation, 14 T.C. 313, 320; Perel & Lowenstein, Inc. v. Commissioner, 237 F. 2d 908 (C.A. 6, 1956), affirming per curiam a Memorandum Opinion of this Court. On the second issue the material pr…
  9. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  10. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …it used by plan’s actuary 1981 $50,000 $1,950.00 $1,950.00 $30,000 $1,950.00 1982 35,150 1,370.85 3,320.85 37.500 3,320.85 1983 262,000 10,218.00 13.538.85 45,000 13.538.85 1984 370,000 14,430.00 27.968.85 52.500 27.968.86 1985 27,968.85 60,000 27,968.85 1986 27.968.85 67.500 27.968.85 1987 200,000 20,000.00 47.968.85 …
  11. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    ax of $3,000.60 because she received.the distributions before she attained age 59-1/2 and the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v). Discussion Summary judgment is intended to.expedite litigation and avoid unnecessary and expensive trials and may be granted where the…
  12. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    …ivalent cost of $104 million. The total three-year average hour burden for plans is estimated to be 320,000 hours with an equivalent cost of $20.1 million. The total three-year average hour burden of the regulation is estimated to be 1.7 million hours with an equivalent cost of $124 million. Table 12—Hour Burden   Year…
  13. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
  14. Treas. Reg. § 1.417(e)-1(d)(7)(v)(E) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …nce factors, Participant W's accrued benefit derived from the cash balance hypothetical account is $320 per month, payable as a straight life annuity at normal retirement age. Participant W elects to receive 1/3 or $15,000 of the current hypothetical account balance in the form of a single sum and to receive the remain…
  15. IRCCourt RulingsAug 3, 1979related by meaning
    istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
  16. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …2,572,500 Rule Review (In-House) 80,137 = 801,370 Plans × 10% Not Using a Service Provider 4 181.06 320,548 58,038,421 Total 334,756 60,610,921 (2) 2002 Safe Harbor: Notice for New Participants and Beneficiaries SECURE 2.0 requires that participants and beneficiaries covered under the 2002 safe harbor, who are newly el…
  17. T.C. Summary Opinion 2015-48 — Joshua W. Pingel v. Commissioner
    IRCCourt RulingsAug 10, 2015related by meaning
    mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo. 2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144. - 12 - II. Section 1839 A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and necessary expenses incurred in conducting a trade or business or for the production of income. Se…
  18. 88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCFinal Rules (FR)Dec 21, 2023
    …based on the Departments' experience operating the Federal IDR process, significantly fewer than 67,320 small providers and facilities have accessed the process to date,[159] the Departments lack adequate data to better inform the number of small providers impacted by these final rules. Therefore, although the estimate…
  19. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  20. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    2011), 320, https://www.nber.org/​system/​files/​working_​papers/​w17664/​w17664.pdf. Back to Citation 571.  For example: Randall A. Heron & Erik Lie, Does Backdating Explain the Stock Price Pattern Around Executive Stock Option Grants?, 83(2) Journal of Financial Economics 271-295 (2007).; Randall A. Heron & Erik Lie,…