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21. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…
22. 89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file numb…
23. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    t C. Slaton purports to extend the period of limitations for 1983 only. Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
24. 91 FR 55462 — Federal Independent Dispute Resolution Operations; Correction
    IRCFinal Rules (FR)Aug 28, 2026related by meaning
    on, Publications and Regulations, Associate Chief Counsel, (Procedure and Administration) Department of the Treasury. In concurrence: Kurt D. Dykstra, General Counsel, Office of Personnel Management. [FR Doc. 2026-17622 Filed 8-27-26; 8:45 am] BILLING CODE 6325-63-P; 4831-GV-P; 4510-29-P; 4169-69-P
25. 69 T.C. 773 — Lansons, Inc. v. Commissioner
    IRCCourt RulingsFeb 27, 1978
    …ee because of the minimum wage requirement; she earned $480 during the fiscal year ending August 31,1968. However, despite elimination of the minimum wage requirement she still was not covered under the amended plan because of the minimum age requirement. As a result of this mistake, in lieu of having 10 covered employ…
26. 60 T.C. 469; 60 T.C. No. 52 — Estate of Bell v. Commissioner
    IRCCourt RulingsJun 26, 1973
    …Judge: Respondent determined the following deficiencies in petitioners’ income tax: Year Deficiency 1968 _$1, 931. 91 1969 _ 2, 926.11 Some of the facts have been stipulated by the parties and are incorporated herein by reference. As a result of concessions made by the parties, the following issues remain for decision:…
27. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    e been provided. Accordingly, the Committee believes it appropriate to apply an early withdrawal tax to all tax-favored retirement arrangements. * * * S. Rept. No. 99-313, supra at 613, 1986-3 C.B. (Vol. 3) at 613. Similarly, in connection with the enactment of a prior version of section 72(m)(5),8 which pre-dated sect…
28. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …ussion of the Retirement System and the Pension System, see generally Hylton v. Commissioner , T.C. Memo. 1995-27; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , T.C. Memo. 1994-633; Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 1357-1358 (D. Md. 1984). 4 So stipulated.
29. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    ication of a pending or planned examination or investigation as a result of information provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010). Additionally, the Tax Court has exclusive jurisdiction over appeals of award determinations where a whistleblower provided information both before and after the effectiv…
30. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
31. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
32. Treas. Reg. § 1.72-17(ii)(iv) — Special rules applicable to owner-employees.
    IRCRegulationsJul 26, 2016
    …963. Until the end of 1967, B's interest in the partnership was less than 10 percent. On January 1, 1968, B obtained an interest in excess of 10 percent in the partnership and continued to participate in the profit-sharing plan until 1972. During 1972, prior to the time he attained the age of 59 1/2 years and during a …
33. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998related by meaning
    …is case would lie, stated in Roundy v. Commissioner , 122 F.3d 835, 837 (9th Cir. 1997), affg. T.C. Memo. 1995-298: [Section 72(t)(1)] applies to any retirement distribution, so long as it is not specifically exempted and is from a "qualified retirement plan". Petitioner has not disputed that the distribution in issue …
34. 90 FR 28004 — Removal of Interpretive Bulletins Relating to the Employee Retirement Income Security Act of 1974
    ERISAFinal Rules (FR)Jul 1, 2025related by meaning
    977) (“The attention of interested parties is directed to the fact that regulation 2550.408c-2 replaces Interpretive Bulletin 75-6”). Back to Citation 7.  41 FR 3289 (Jan. 22, 1976). Back to Citation 8.  43 FR 47713 (Oct. 17, 1978). Congress subsequently ratified Reorganization Plan No. 4 in 1984. See Sec. 1, Public La…
35. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003related by meaning
    rders) applies for transfers, distributions, and payments made after December 31, 2001. Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
36. 90 FR 28007 — Selection of Annuity Providers-Safe Harbor for Individual Account Plans
    ERISAFinal Rules (FR)Jul 1, 2025related by meaning
    …plicable policies in those guidelines. J. Review Under Additional Executive Orders and Presidential Memoranda
37. 54 T.C. 1057 — Bernard McMenamy, Contractor, Inc. v. Commissioner
    IRCCourt RulingsMay 25, 1970
    …gulations was adopted, the respondent issued I.T. 3685, 1944 C.B. 324, restated in Rev. Rul. 68-653,1968-2 C.B. 177; I.T. 3686, 1944 C.B. 326, restated in Rev. Rul. 68-654, 1968-2 C.B. 179; and P.S. No. 28 (1944), restated in Rev. Rul. 68-652, 1968-2 C.B. 176. In these rulings, he made clear that in his opinion, prohib…
38. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
39. 62 T.C. 621; 62 T.C. No. 71 — Liberty Machine Works, Inc. v. Commissioner
    IRCCourt RulingsAug 19, 1974
    , 1968, petitioner adopted a profit-sharing plan and trust. The pertinent portions of the profit-sharing plan are as follows: Article II * * * * * * * The Trustees shall allocate annually sums set aside by the Company as hereinafter provided to the respective accounts of such of the full time clerical and salaried empl…