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41. 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…
42. 83 FR 38212 — Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Aug 3, 2018
    …e” in § 144.103 of this subchapter is applicable October 2, 2018. Footnotes 1.  Public Law 104-191, 110 Stat. 1936 (August 21, 1996). Back to Citation 2.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 3.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 4.  Public Law 1…
43. 83 FR 7437 — Short-Term, Limited-Duration Insurance
    IRCProposed Rules (FR)Proposed Feb 21, 2018
    … DATE OF PUBLICATION OF THE FINAL RULE IN THE FEDERAL REGISTER ]. Footnotes 1.  Public Law 104-191, 110 Stat. 1936 (August 21, 1996). Back to Citation 2.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 3.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 4.  Public Law 1…
44. 81 FR 47534 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    …e enactment of the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, 110 Stat. 1936 (Aug. 21, 1996); Title I of the Genetic Information Nondiscrimination Act of 2008, Public Law 110-233, 122 Stat. 881 (May 21, 2008); the Mental Health Parity Act of 1996, Public Law 104-204, 110 Stat. 2944…
45. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
46. 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…
47. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
48. Treas. Reg. § 1.430(g)-1(c)(2)(iii)(A) — Valuation date and valuation of plan assets.
    IRCRegulationsSep 9, 2016
    (c)(2)(iii)(A) (A) In general. This paragraph (c)(2)(iii) provides rules for applying the 90 to 110 percent corridor set forth in section 430(g)(3)(B)(iii). The rules for accounting for contribution receipts under paragraphs (d)(1) and (d)(2) of this section are applied prior to the application of the 90 to 110 percent…
49. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021
    …h the funds transferred from the MetLife annuity. Mrs. McNulty instructed Kingdom Trust to purchase 375,000 m em bership units of Green Hill at $1 per unit for an investm ent of $375,000. The funds for the
50. Treas. Reg. § 54.9815-2719A(b)(3)(iv) — Patient protections.
    IRCRegulationsDec 30, 2016
    3, the values taken into account in determining the median are $85, $100, $100, $110, $110, $120, $120, $120, and $150. Therefore, the median amount among those agreed to for the emergency service is $110, and the amount under paragraph (b)(3)(i)(A) of this section is 80% of $110 ($88). Example 4.(i) Facts. Same facts …
51. 78 FR 77632 — Amendments to Excepted Benefits
    IRCProposed Rules (FR)Proposed Dec 24, 2013
    … no cost sharing under the employee assistance program. * * * * * Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
52. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …al Holdings II, LLC, of Bonus Energy Sdn Bhd (the company that owned Octazen in February 2010) for $375,000 and three milestone payments in the future. 33 In February 2010 Facebook US recorded an intangible asset purchase for $375,000 under the description “Octazen acquisition.” 34
53. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
54. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    sonable compensation and therefore not deductible under section 162 (and thereby section 404), the 10% section 4972 excise tax applies to that extent. V. Section 6651(a)(1) and (2) Additions to Tax Respondent contends that the corporation is liable for section 6651(a)(1) failure to file additions to tax of $10,050.95 a…
55. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    applies only to the extent that it fits within the flush language or one of the referenced exceptions. - 106 - E. Reasonable Cause 1. Section 6662(a) a. Overview An accuracy-related penalty under section 6662(a) is not appropriate in a case where a taxpayer demonstrates that reasonable cause existed for an underpaymen…
56. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    strictions. Section __.110(b) requires preparation of a plan for remediation to achieve an NSFR of at least equal to 1.0, as required under §  __.100. Section __.130 requires that a depository institution holding company subject to the NSFR publicly disclose on a biannual basis its NSFR calculated for each of the two i…
57. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
58. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
59. 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 …
60. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…