50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…2,765,372
Participants
11,100,000
14,500,000
9,100,000
134,800,000
Cost Savings
$33,073,808
$43,204,523
$27,114,563
$401,653,086
Cost Savings Per Plan
$23.49
$71.25
$48.21
$145.24
Cost Savings Per Plan as a Share of Premium
0.0168%
0.0213%
0.0035%
( printed page 46629)
E. Alternatives
1. Exempting Smaller Plans From th…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…ignated investment alternatives in an individual account plan.
See Tibble
v.
Edison Int'l,
575 U.S. 523, 529 (2015).
2.4.2. Duty of Prudence Focuses on Process at the Time of the Decision
The defining characteristic of the duty of prudence is that it is “largely a process-based inquiry.”
Smith
v.
CommonSpirit Health,
3…
IRCCourt RulingsSep 24, 2007related by meaning
T .C . Memo . 2007-292
UNITED STATES TAX COUR T
HUBERT JOUBERT, Petitioner V .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 8769-06 . Filed September 24, 2007 .
P failed to file a Federal income tax return for 2002 .
R determined a deficiency and asserted in the notic e
deficiency, the answer, and the pret…
IRCCourt RulingsDec 18, 2012
…' gross income for the subject years includes
"unreported income" of $11,122, $22,520, $8,502, $155,523, $110,720, and
$88,965, respectively.5 We hold that it does;
5For this purpose, respondent used the description "unreported income" to
refer to income that was neither nonemployee compensation, rental income,
interes…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…ns
3,872,016 = ((
1/3 ) × 15,385,053 Participants in non-frozen DB plans under 2020 safe harbor + 3,523,231 Participants in frozen DB plans under 2020 safe harbor) × (96.1% Pre-Statute E-Disclosure Rate−51.3% Post-Statute E-Disclosure Rate)
1
$0.05
$1.00
$4,065,617
Distribution of Statements for DC Plans
34,367,195 = 7…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
ERISACourt RulingsAug 31, 2026
…through the
plan itself .” Id. at 301 (citation omitted); Standard Ins. Co. v. Guy , 115 F.4th 518, 523 (6th Cir. 2024) . B ecause the
Complaint plausibly alleges that the decedent used the P lan’s
designated mechanism , this case is governed by Becker.
7
Nor does this case implicate one concern “central to the Supreme…
IRCCourt RulingsJul 13, 2010related by meaning
.a distribution
of $6,277 from a qualified retirement . plan during~the'2001 tax
year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that
she qualified for any of the . exceptions in section 72(t)(2) .
Accordingly ; we hold that Ms .-O'Boyle…
IRCCourt RulingsMay 9, 2002related by meaning
ven report
the distributions.
the clear intent of Congress to prevent voluntary withdrawals, we
decided that the penalty was inapplicable. Id.
at 291. Petitioners’ reliance on Larotonda v. Commissioner
, supra
,
is misplaced. Here, respondent did not levy on the retirement
accounts. Petitioners made voluntary withdrawa…
IRCCourt RulingsDec 11, 1997related by meaning
o be
treated as an amount received as a loan on the date of such
renegotiation, extension, renewal, or revision. TEFRA, sec.
236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2)
if it (1) is in an amount not exceeding a prescribed ceiling that
in no event may be more than $50,000, …
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
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 …
IRCCourt RulingsMar 7, 2019
…orate returns for the years at
issue:
Year Total income Total deductions Taxable income
2003 $1,643,523 $1,550,807 $92,716
2004 1,488,793 1,390,853 97,940
2005 1,688,916 1,693,882 (4,966)
2006 1,903,914 1,884,065 14,883¹4
¹³ BAI's fiscal year ends June 30. Therefore, all references to BAI's tax
years at issue refer to …
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
… remain, so the burden of proof is
irrelevant. See, e.g. , Nis Fam . Tr. v. Commiss ioner, 115 T.C. 523, 538
(2000).
III. Whether Hoops Is Entitled to a Deduction for the Deferred
Compens ation Liability in 2012
Section 162(a) allows a deduction for all ordinary and necessary
expenses paid or incurred during the taxabl…
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…
IRCCourt RulingsMay 1, 1996
…r
section 72(e)(2). Guilzon v. Commissioner
, supra
at 242-243;
Shimota v. United States
, supra
at 523.
Petitioners’ argument that double taxation will occur is
IRCCourt RulingsJan 2, 2020related by meaning
relevant times, and all Rule references are to
the Tax Court Rules of Practice and Procedure. All monetary amounts are
rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross
income rental income of $4,920 they received in 2007.
- 3 -
[*3] to deduct a net operating loss (…
IRCCourt RulingsJun 13, 2017
…s remain, so the burden of proof is irrelevant. See, e.g., Nis Family Tr.
v. Commissioner, 115 T.C. 523, 538 (2000).
Generally, an accrual basis taxpayer may deduct ordinary and necessary
business expenses in the year when all events have occurred that establish the fact
of the liability, the amount of the liability is…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…