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93 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016★ strong match
    …etween the taxpayers and the IRAs. See 4 at 224-225; see also Janpol v. Commissioner, 101 T.C. 518, 527 (1993) ("An individual who guarantees repayment of a loan extended by a third party to a debtor is, although indirectly, extending credit to the debtor."). The Court held that the taxpayers' participation in the proh…
  2. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013★ strong match
    …006; or (4) when Mr. Ellis 18Petitioners' return as originally filed reflected an overpayment of $1,527 for tax year 2006. Respondent has asserted that petitioners will be liable for the addition to tax under sec. 6651(a)(1) only to the extent the Court determines a deficiency for tax year 2006. - 14 - [*14] caused CST…
  3. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
  4. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    spouse, child, or other dependent of a participant, and (ii) is made pursuant to a State domestic relations law (including a community property law). “The reason that many ERISA sections have such counterparts in the IRC is that, to encourage employers to establish pension plans, Congress provides favorable tax treatme…
  5. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …notice of deficiency that petitioner paid mortgage interest of $36,829 and therefore disallowed $17,527 of the amount claimed on Schedule A, $54,356. In contrast, respondent did not disallow any part of petitioner's deduction for medical expenses other. than to adjust the amount of the deduction in order to reflect the…
  6. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  7. 85 FR 42782 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage
    IRCProposed Rules (FR)Proposed Jul 15, 2020
    … multiplied by the percentage of entities offering grandfathered health plans (2.4 million * 0.22 = 527,000), the number of state and local governments multiplied by the percentage of entities offering grandfathered health plans (83,500 * 0.22 = 18,400), and the 834 issuers offering at least one grandfathered health pl…
  8. 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…
  9. 76 FR 74699 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 1, 2011
    … at URA is greater than— From— To— 2013 575 575 2,431 2,431 2014 586 586 2,477 2,477 2015 598 598 2,527 2,527 2016 610 610 2,577 2,577 2017 623 623 2,632 2,632 2018 636 636 2,687 2,687 2019 649 649 2,743 2,743 2020 663 663 2,801 2,801 2021 677 677 2,860 2,860 2022 or later 691 691 2,920 2,920 1 Table II-A. 2 Table II-B…
  10. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  11. T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 23, 2022
    …by Congress. Judge v. Commissioner, 88 T.C. 1175, 1180 – 81 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). We nevertheless have jurisdiction to determine whether we have jurisdiction. Hambrick v. Commissioner, 118 T.C. 348, 350 (2002); Pyo v. Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83 T…
  12. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  13. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …his ruling." M (quoting Gilles, 521 P.2d at 116); see also Quinlivan v. Sullivan, 916 F.2d 524, 526-527 (9th Cir. 1990)
  14. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  15. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998
    …orized by Congress. Neilson v. Commissioner , 94 T.C. 1, 9 (1990); Naftel v. Commissioner , 85 T.C. 527, 529 (1985); see also sec. 7442. Whether we have jurisdiction over the subject matter of a dispute is an issue that either party thereto, or this or an appellate court sua sponte, may raise at any time. The failure t…
  16. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  17. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …icated: Taxable Year Claimed Home Mortgage Interest and Points Claimed Investment Interest 1991 $22,527 $156,708
  18. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999
    …atute. See Judge v. Commissioner , 88 T.C. 1175, 1180-1181 (1987); Naftel v. Commissioner , 85 T.C. 527, 529 (1985). This Court's jurisdiction - 8 - to redetermine a deficiency in tax generally does not extend to statutory interest imposed under section 6601. See Bax v. Commissioner , 13 F.3d 54, 56-57 (2d Cir. 1993), …
  19. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  20. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024
    …urisdiction only to the extent authorized by Congress. See § 7442 ; Naftel v. Commissioner, 85 T.C. 527, 529 ( 1985) . In a deficiency case , our jurisdiction is predicated on a valid notice of