Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 79 T.C. 985 (not yet in the library — opens the official source)
90 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    OPINION COHEN, Judge: Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
  2. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  3. 85 FR 40834 — Improving Investment Advice for Workers & Retirees
    ERISAProposed Rules (FR)Proposed Jul 7, 2020
    pact of the proposed exemption on small entities. In December 2018, there were 985 small-business BDs and 528 SEC-registered, small-business IAs.[175] The Department estimates that approximately 52 percent of these small-businesses will be affected by the proposed exemption.[176] In December 2018, the Department estima…
  4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    letcher 1973-1983 -0- -01984 $6,000 -01985 13,000 $12,923 1986 15,521 18,764 1987 26,769 29,077 1988 36,000 36,000 1989 36,000 36,000 1990 4,154 4,154 1991 -0- -01992 20,800 -01993 20,800 -06All amounts have been rounded to the nearest whole number. No Forms W2 were presented for any year where the amount paid was "-0-…
  5. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    GOFFE, Judge: The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
  6. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …t. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4,789,467 30,420,770 B. Suspense Account transactions
  7. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  8. Rev. Proc. 2017-18 — This revenue procedure provides that the last day of the remedial amendment period for § 403(b) plans, for purposes of section 21 of Rev. Proc. 2013–22, 2013–1…
    IRCRevenue ProceduresModified Jan 30, 2017
    …endment period for § 403(b) plans, for purposes of section 21 of Rev. Proc. 2013–22, 2013-18 I.R.B. 985, is March 31, 2020. The selection of the last day of the remedial amendment period for § 403(b) plans was reserved in section 21 of Rev. Proc. 2013–22 (setting forth the procedures for issuing opinion and advisory le…
  9. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    tioners to believe that no taxable event was created by the above transactions for which any Federal excise tax returns would be required to be filed. On November 21, 1986, respondent issued a notice of deficiency to each petitioner, in the amounts set forth above, determining an excise tax pursuant to section 4975(a).…
  10. Rev. Proc. 2015-22 — This revenue procedure contains a modification to Revenue Procedure 2013–22, 2013–18 I.R.B. 985, as modified by Revenue Procedure 2014–28, 2014–16 I.R.B. 944, …
    IRCRevenue ProceduresMar 16, 2015
    …PURPOSE This revenue procedure contains a modification to Revenue Procedure 2013–22, 2013–18 I.R.B. 985, as modified by Revenue Procedure 2014–28, 2014–16 I.R.B. 944, and modifications to Revenue Procedure 2015–8, 2015–1 I.R.B. 235. In particular, this revenue procedure changes the addresses to which applications for o…
  11. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …- 11 - [*11] Account 1992 1993 1994 1995 1996 1997 BOA3721 -0- $3,206 $2,000 $875 -0- -0BOA3886 $66,985 28,531 15,793 224,873 $73,281 $11,593 CB9250 -0- -0- 68,843 15,900 15,716 -0FFB0488 -0- 400,296 221,847 -0- -0- -0FFB0991 -0- -0- -0- 500 -0- -0FFB1604 -0- -0- 415,339 769,501 519,925 -0FFB2520 -0- -0- -0- 139,412 84…
  12. Rev. Proc. 2014-28 — This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing o…
    IRCRevenue ProceduresApr 14, 2014
    …Proc. 2014–28 SECTION 1. PURPOSE This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing opinion and advisory letters for § 403(b) pre-approved plans (that is, § 403(b) prototype plans and § 403(b) volume submitter pla…
  13. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …ors 20 See § 7463(b) ; Rule 170; Golsen v. Commissioner, 54 T.C. 742, 757 (1970), aff’ d , 445 F.2d 985 (10th Cir. 1971). 22 do not apply or are neutral . No single factor or group of factors is dispositive , and more weight may be given to some factors than others. Golanty , 72 T.C. at 426; see also Surridge v. Commis…
  14. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    …r the 1991 excise tax deficiency. Sec. 6213; Stamm Intl. Corp. v. Commissioner , 84 T.C. 248, 252 (1985). Questions of jurisdiction must be decided whenever it appears that we may not have jurisdiction. Wheeler's Peachtree Pharmacy, Inc. v. Commissioner , 35 T.C. 177, 179 (1960). Section 6212, in pertinent part, provid…
  15. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …nts) 401,392 293,016 108,376 210,739 Fully insured (States without Requirements) 314,761 229,775 84,985 165,256 Total Private 933,803 681,677 252,127 490,266 All Plans 995,792 726,928 268,864 522,811 * Totals displayed in the table may not sum due to rounding. 1  Estimated from the KFF
  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
    …615,037 Additional Paper DC Statement Cost (5 Pages) $0 $42,958,993 $37,214,880 $34,420,082 $38,197,985 Total Additional Costs $0 $47,024,610 $40,736,877 $37,677,581 $41,813,022 Table 15—Pension Benefit Statement Burden Summary   Hourly burden Cost burden Baseline Burden to Distribute Benefit Statements $374,708,891 Ad…
  17. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  18. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    …of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equaling one-half" of her former spouse's Coast Guard retirement p…
  19. PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsSep 25, 2009
    … money periodically over a term of years or for life. See , e.g ., Bodine v. Comm’r , 103 F.2d 982, 985 (3d Cir.), cert. denied , 308 U.S. 576 (1939) (“[A]n annuity may be described as a sum paid yearly or at other specified intervals in return for the payment of a fixed sum by the annuitant.”); Manne v. Comm’r , 155 F…
  20. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    … that he is entitled to judgment as a matter of law. See Naftel v. Commissioner, 85 T.C. 527, 529 (1985). In deciding whether summary judgment is appropriate, we view the factual materials and the inferences drawn therefrom in the light most favorable to the nonmoving party. United States v. Diebold, Inc., 369 U.S. 654…