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21. 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).…
22. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …issioner , 856 F.2d 855, 860 (7th Cir. 1988), rev’g in par t on other grounds and remanding 84 T.C. 996 (1985); and then
23. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
24. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
25. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    …ry 1, 2020), determined using a five percent interest rate, is $84,758 as of December 31, 2015; $88,996 as of December 31, 2016; $93,446 as of December 31, 2017; and $57,143 as of December 31, 2018. However, for purposes of determining the increase in the present value of the future payments during 2018 (the year of th…
26. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
27. 72 T.C. 768; 1 Employee Benefits Cas. (BNA) 1603 — Guest v. Commissioner
    IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
28. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992related by meaning
    etitioner Docket No. Year ended Deficiency Sec. 6651(a)(1) Sec. 6659A Citrus Valley Estates, Ine. et al. 12900-89 12/31/82 $6,182.00 12/31/83 5,737.00 12/31/85 22,462.00 24352-90 12/31/88 4,265.00 - - - $1,280.00 Additions to tax Petitioner Docket No. Year ended Deficiency Sec. 6651(a)(1) Sec. 6659A Robert J. & Janice …
29. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    tion that petitioners are liable for the 10-percent additional tax imposed by section 72(t). Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of Additional Tax.--If an…
30. 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…
31. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …y 1, 1987. The total of all America/Bradley partners' capital accounts decreased from a deficit of $996,674 at the beginning of 1987 to a deficit of $2,853,708 at the end of
32. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e not binding on any government agency other than the United States Department of Labor." On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise tax deficiencies pursuant to section 4975(a) and (b), as well as additions to tax. Respondent determine…
33. Treas. Reg. § 1.401(l)-3(e)(3) — Permitted disparity for defined benefit plans.
    IRCRegulationsMay 18, 2016
    …al factor in maximum excess allowance and maximum offset allowance (percent) 70 1.209 69 1.096 68 0.996 67 0.905 66 0.824 65 0.750 64 0.700 63 0.650 62 0.600 61 0.550 60 0.500 59 0.475 58 0.450 57 0.425 56 0.400 55 0.375 Table IV[Simplified table] Age at which benefits commence Annual factor in maximum excess allowance…
34. 29 C.F.R. § 2530.200a-2 — Treasury regulations for purposes of the Act.
    ERISARegulationsJan 1, 2017
    …tary of Labor is governed by titles I through III of the Act. See section 3002 of the Act (88 Stat. 996).
35. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    ualified retirement plan within the meaning of sec. 4974(c). In the light of our holding that the "additional tax" under sec. 72(t) is not a "penalty, addition to tax, or additional amount" under sec. 7491(c), we deem this issue conceded. - 11 - received the deemed distribution or that any other exception in section 72…
36. 29 C.F.R. § 2530.200a-3 — Labor regulations for purposes of the Internal Revenue Code of 1954.
    ERISARegulationsJan 1, 2017
    … his delegate is governed by titles I through III of the Act. See section 3002 of the Act (88 Stat. 996).
37. 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 …
38. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …l as one element of the deficiency determination. See Estate of Gardner v. Commissioner, 82 T.C. at 996. ¹°Mailman v. Commissioner, 91 T.C. 1079, 1082 (1988), makes it clear that
39. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …equirements) 20,156 14,714 5,442 10,582 Small Fully insured (States without Requirements) 27,391 19,996 7,396 14,381 Total Small Public 57,897 42,265 15,632 30,397 Small Private Entities: Small Self-insured (States with Requirements) 176,478 128,829 47,649 92,654 ( printed page 27167) Small Self-insured (States without…
40. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    did not consider the precedential effect of Beech Trucking Co. v. Commissioner, 118 T.C. 428 (2002) (Beech Trucking Co.), and (b) the factors used in determining whether a person is an employer or an employee24 that the Court applied in Transport Labor I were inconsistent with the common-law employment factors applied…