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21. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …05 -0Mortg. interest 6,503.89 6,503.89 6,503.89 -0Repairs 4,112.10 5,487.10 5,487.10 -0Taxes 220.00 435.43 435.43 -0Utilities 3,837.35 5,503.09 5,503.09 -0Telephone 587.75 -0- 1,342.33 (1,342.33) Miscellaneous -0- 8,331.42 -0- 8,331.42 Meals -0- -0- 662.73 (662.73) Depreciation 2,248.00 2,889.00 2,889.00 -0- Total 20,6…
22. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …treated as a sham and disregarded for Federal income tax purposes. Frank Lyon Co. v. United States, 435 U.S. 561 (1978); Rice's Toyota World, Inc., 81 T.C. at 196. The economic substance of a transaction, rather than its form, controls. Frank Lyon Co., 435 U.S. at 583-584; Derr v. Commissioner, 77 T.C. 708 (1981). The …
23. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
24. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
25. 53 T.C. 385 — Loper Sheet Metal, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1969
    …me tax returns of the years ending October 31, 1963, 1964, and 1965, petitioner deducted $7,140, $9,435, and $7,200, respectively, as contributions to the trust established under its profit-sharing plan. The respondent by notice of deficiency mailed April 12, 1967, disallowed these deductions in toto. OPINION Petitione…
26. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
27. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …NDOPCO, Inc. v. Commissioner , 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering , 292 U.S. 435, 440 (1934). A taxpayer claiming a deduction must demonstrate both that the deduction is allowable
28. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
    IRCRegulationsJul 12, 2016
    …0 1979 900,000 (20% of $500,000 + 15% of $400,000=) 160,000 264,000 40,000 50,000 Totals: 2,400,000 435,000 670,750 108,750 115,000 (2) Organization Y, whose taxable year is the calendar year, was first treated as an organization described in section 501(c)(3) on February 1, 1977. Y made the expenditure test election u…
29. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ities. Classification of the transaction as a prohibited transaction under section 408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is subject to a 10-percent additional tax. See secs. 72(t), 408(e) (2) (]B). In cases where the Service att…
30. 78 FR 13781 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities
    ERISAFinal Rules (FR)Mar 1, 2013
    percent of the 484 entities (435 entities) that will file the Form M-1 will use third-party service providers to complete and submit the Form M-1.[27] Because the Department is adding additional data elements to the form, the Department assumes that in the year of implementation, all service providers would spend addit…
31. 29 C.F.R. § 2510.3-40(e) — Plans Established or Maintained Under or Pursuant to Collective Bargaining Agreements Under Section 3(40)(A) of ERISA.
    ERISARegulationsJan 1, 2017
    …CBA-alumni 100 (20%) 50 (10%) 50 (10%) 4. Non-nexus participants 15 (3%) 0 15 (3%) Total 500 (100%) 435 (87%) 65 (13%) In determining whether at least 85% of Plan A's participant population is made up of individuals with the required nexus to the collective bargaining agreement as required by paragraph (b)(2) of this s…
32. 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. …
33. 29 C.F.R. § 2530.200b-3(d) — Determination of service to be credited to employees.
    ERISARegulationsJan 1, 2017
    …(3)(i) of this section, if 870 hours worked are treated as equivalent to 1,000 hours of service and 435 hours worked are treated as equivalent to 500 hours of service. (d)(2) (2) Regular time hours. A plan may determine service to be credited to an employee on the basis of regular time hours, as defined in paragraph (d…
34. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
35. 88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    … burden cost Burden hours Equivalent burden cost Legal 5,992 $954,765 5,992 $954,765 Clerical 101 6,435 101 6,435 Total 6,093 961,200 6,093 961,200 The Department assumes that this information will include seven pages with 94.2 percent of disclosures distributed electronically through traditional electronic methods at …
36. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
37. PLR 201240018 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsOct 5, 2012
    …22 The Service found investor control when (1) the 17 See , e.g. , Frank Lyon Co. v. United States, 435 U.S. 561, 572-73 (1978); Helvering v. F. & R. Lazarus & Co ., 308 U.S. 252 (1939); Helvering v. Clifford, 309 U.S. 331, 335 (1940); Sun Oil Co. v. Comm’r, 562 F.2d 258, 263, 269 (3d Cir. 1977); Bailey v. Commissioner…
38. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
39. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
40. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […