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91 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  2. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …note); sec. 512(d), Pub. L. 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Pub. L. 111-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029; Division M, Pub. L. 113-235, 128 Stat. 2130; Pub. L. 116-260, 134 Stat. 1182; Secretary of Labor's Order 1-2011, 77 F. R. 1088 (Jan. 9, 2012). 4. Section 2590…
  3. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  4. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …note); sec. 512(d), Pub. L. 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Pub. L. 111-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029; Division M, Pub. L. 113-235, 128 Stat. 2130; Pub. L. 116-260, 134 Stat. 1182; Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). 6. Section 2590.71…
  5. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  6. T.C. Summary Opinion 2019-19 — Lily Hilda Soltani-Amadi & Bahman Justin Amadi v. Commissioner
    IRCCourt RulingsAug 8, 2019
    …ement plans, such as section 401(k) retirement plans. See Uscinski v. Commissioner, T.C. Memo. 2005-124. As has already been discussed, section 72(t)(1) serves to impose the 10% additional tax on "qualified retirement plans" as defined in section 4974(c), and such plans include both section 401(k) retirement plans and …
  7. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  8. 132 T.C. No. 15 — Gregory T. & Kim D. Benz v. Commissioner
    IRCCourt RulingsMay 11, 2009
    . Individual Income Tax Return, for 2004, reporting-the $124,811 .5 .0 in distributions from petitioner wife's IRA during 2004 . Petitioners did not 4 report the 10-percent additional tax for an early withdrawal from an IRA pursuant to section 72(t) with respect to any portion of the distributions . Petitioners attache…
  9. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  10. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …tion...................................... 123 2. Events .......................................... 124 3. Analysis and holding............................... 124 AA. Period 17: December 8, 2010, through January 3, 2011 . . . . . . . . 125 1. Introduction...................................... 125 2. Events ............…
  11. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015
    …rguing that the gains and interest were exempt from garnishment under Haw. Rev. Stat. Ann. sec. 651-124.6 The magistrate judge disagreed with petitioner and held that the gains and interest 6 Haw. Rev. Stat. Ann. sec. 651-124 (LexisNexis 2012) exempts from attachment, execution or seizure, the rights of a debtor to a p…
  12. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  13. 79 FR 35942 — Ninety-Day Waiting Period Limitation
    IRCFinal Rules (FR)Jun 25, 2014
    … sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services regulations are adopted pursuant to the au…
  14. T.C. Memo. 2019-124 — William Elias Rosenberg v. Commissioner
    IRCCourt RulingsSep 19, 2019
    RS T.C. Memo. 2019-124 UNITED STATES TAX COURT WILLIAM ELIAS ROSENBERG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23628-17. Filed September 19, 2019. William Elias Rosenberg, pro se. Caitlin A. Homewood, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PUGH, Judge: In a notice of defi…
  15. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  16. 79 FR 26192 — Health Care Continuation Coverage
    ERISAProposed Rules (FR)Proposed May 7, 2014
    …note); sec. 512(d), Pub. L. 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Pub. L. 111-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029; Secretary of Labor's Order 1-2011, 77 FR 1088 (January 9, 2012). List of Subjects in 29 CFR Part 2590 Continuation coverage Disclosure Employee benefit plans …
  17. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    tion to be carried out with respect to whether the tax imposed by section 4975 of Title 26 should be applied to any person referred to in the request. Because our Rules do not recognize a motion to limit a deficiency determination, petitioners’ request should have been cast as a motion for partial summary judgment unde…
  18. 79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCFinal Rules (FR)Feb 24, 2014
    … sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services regulations are adopted, with respect to 4…
  19. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980related by meaning
    nstant case — to avoid the section 4973 excise tax. We hold that Johnson is liable for the asserted excise taxes under section 4973 for 1975 and 1976. It appears that the notice of deficiency addressed to petitioners may be understood as asserting joint liabilities for the excise tax deficiencies. (See n.l supra) Since…
  20. 79 FR 10320 — Ninety-Day Waiting Period Limitation
    IRCProposed Rules (FR)Proposed Feb 24, 2014
    … sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services regulations are proposed to be adopted pur…