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21. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
22. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …iary . ” Dawson - Murdock, 931 F.3d at 276 (quoting Tatum v. RJR Pension Inv. Comm. , 761 F.3d 346, 357 n.6 (4th Cir. 2014)) . Even i f not named as a fiduciary in the plan , a person or entity may be a functional fiduciary
23. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …he factors the experts considered in reaching their conclusions. See Casey v. Commissioner, 38 T.C. 357, 381 (1962). We are not bound by an expert’s opinion that we find contrary to our judgment, and we can accept an expert’s opinion in its entirety or accept aspects of the expert’s testimony that we find reliable. Ran…
24. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …iary . ” Dawson - Murdock, 931 F.3d at 276 (quoting Tatum v. RJR Pension Inv. Comm. , 761 F.3d 346, 357 n.6 (4th Cir. 2014)) . Even i f not named as a fiduciary in the plan , a person or entity may be a functional fiduciary
25. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    …90 .435 .480 .525 51 .066 .129 .188 .244 .298 .351 .397 .443 .489 .535 52 .067 .131 .191 .248 .303 .357 .404 .451 .498 .545 53 .068 .133 .194 .252 .308 .363 .411 .459 .507 .555 54 .069 .135 .197 .256 .313 .369 .418 .467 .516 .565 55 .070 .137 .200 .260 .318 .375 .425 .475 .525 .575 56 .072 .141 .206 .268 .328 .387 .439…
26. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    tstanding rollover involved in this case. Accordingly, the amount of excludable basis in the instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is $1,950 and the denominator of which is $1,374.53 plus $6,100, resulting in an amount excludable of $1,591.40.…
27. 91 FR 53803 — Determination of Target Normal Cost and Funding Target for Single-Employer Defined Benefit Plans
    IRCProposed Rules (FR)Proposed Aug 20, 2026
    …2017-56, 2017-44 IRB 465 (applicable to single-employer plans), and Rev. Proc. 2000-40, 2000-42 IRB 357 (applicable to multiemployer plans). The Secretary has also prescribed procedures allowing plans to receive automatic approval to change their plan year if certain conditions are met. See Rev. Proc. 87-27, 1987-1 CB …
28. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …5 9,179 1991 38,502 25 9,323 1990 37,146 25 8,943 1989 35,837 25 8,579 1988 34,575 25 8,229 1987 33,357 25 7,894 1986 32,182 25 7,572 1985 31,048 25 7,264 1984 29,955 25 6,968 1983 28,899 25 6,684 1982 27,881 25 6,412 - 17 - [*17] 1981 26,899 25 6,151 1980 25,952 25 5,900 1979 25,037 25 5,660 1978 24,155 25 5,429 1977 …
29. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996
    …ruck & Equipment Corp. v. Commissioner , 98 T.C. l41, 149 (1992); Zinniel v. Commissioner , 89 T.C. 357 (1987),
30. PLR 201240018 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsOct 5, 2012
    …r who could sell the stock to satisfy the claims of its creditors. 19 See Notice 94-47, 1994-1 C.B. 357 (listing factors for distinguishing between debt a nd equity). But see Unocal Corp. v. Kaabipour, 177 F.3d 755, in which the purported leasee in a synthetic lease arrangement " for practical purposes has the attribut…
31. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
32. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsOct 15, 1999
    …change solely for Group stock and the assumption by Company of liabilities of Mutual (§§ 361(a) and 357(a)). (6) Mutual will recognize no gain or loss on the transfer of Group stock to Mutual Members in exchange for their Mutual Member Interests (§ 361(c)). (7) Mutual Members will recognize no gain or loss on the recei…
33. PLR 202315010 — Deferred Compensation
    IRCPrivate Letter RulingsApr 14, 2023
    …so be included in losses under § 832. See State Farm Mut. Auto. Ins. Co. v. Commissioner , 698 F.3d 357 (7th Cir. 2012); Sears, Roebuck & Co. v. Commissioner , 972 F.2d 858 (7th Cir. 1992) , rev.g 96 T.C. 51 (1991). Taxpayer also asserts that a reserve determined in accordance with actuarial standards constitutes a “fa…
34. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    …the tax has been paid;” citing Blair v. Birkenstock , 271 U.S. 348 (1926); Flora v. United States , 357 U.S. 63 (1958). Rev. Proc. 84-58, 1984-2 C.B . 501, explains the procedure for treating remittances as deposits rather than as tax payments, in order to stop the running of interest on deficiencies. 2 A payment made …
35. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
36. 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 …
37. T.C. Summary Opinion 2006-55 — Linda L. & Anthony M. Domanico v. Commissioner
    IRCCourt RulingsApr 19, 2006
    …lphi & St. John’s University $6,273 2000 St. John’s University 11,848 2001 St. John’s University 10,357 2002 Teacher Education Institute 517 2003 Teacher Education Institute 3,152 Total $32,147 During 2001, Mrs. Domanico was also employed as a librarian. TWA informed Mrs. Domanico by letter dated July 25, 2001, that Am…
38. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
39. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
40. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…