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96 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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…
  3. 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…
  4. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    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…
  5. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    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…
  6. 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…
  7. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    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. …
  8. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    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…
  9. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    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…
  10. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    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…
  11. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    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, …
  12. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    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…
  13. 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 …
  14. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    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 …
  15. 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…
  16. 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…
  17. T.C. Memo. 1996-212 — Louis R. & Gregoria S. Gomez v. Commissioner
    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
  18. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    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 (…
  19. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    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…
  20. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    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…