Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 152 T.C. 61 (not yet in the library — opens the official source)
90 documents · 0.33sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  2. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  3. T.C. Summary Opinion 2002-15 — Bryan K. Gauthier v. Commissioner
    IRCCourt RulingsFeb 15, 2002
    spouse, or a dependent (as defined in section 152)”. While petitioner’s mother could have been his dependent, see sec. 152(a)(4), in order for her to qualify as his dependent, petitioner would have had to provide over half of her support, sec. 152(a). We note that not only is the record totally devoid of any evidence …
  4. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
    IRCCourt RulingsSep 19, 1978related by meaning
    dent’s action, at least as to 1970, 1971, and 1973. Cf. Christian Echoes National Ministry, Inc. v. United States, 470 F.2d 849, 858 (10th Cir. 1972). In Ryan School, Sherwood Swan, and Lansons, neither the character of the taxpayer’s business nor the essential composition of its work force changed. In short, these cas…
  5. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    ependent (as defined in section 152) of the taxpayer for the taxable year." Sec. 151(c). Section 152(a) defines a "dependent" to include a "qualifying child". Generally, a "qualifying child" must: (1) bear a specified relationship to the taxpayer; (2) have the same principal place of abode as the taxpayer for more than…
  6. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013
    …poration has a limited number of officers. Charles Schneider & Co. v. Commissioner, 500 F.2d at 151-152. No single factor is dispositive. See Pepsi-Cola Bottling Co. v. Commissioner, 528 F.2d 176, 178 (10th Cir. 1975), aff'g 61 T.C. 564 (1974). Special scrutiny is given in situations where a corporation is controlled b…
  7. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  8. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …d Treasury   Hour burden Cost equivalent of hour burden Cost burden Notice Drafting (Year One) 811 $152,127 Review & Update Notice (Subsequent Years) 406 76,064 Mail Disclosure (Annually) $893,408 First Year Total 811 152,127 893,408 Subsequent Year Total 406 76,064 893,408 Three-Year Average Total 541 101,418 893,408 …
  9. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998
    …termined it was, and, relying primarily on Commissioner v. Keystone Consol. Indus., Inc. , 508 U.S. 152 (1993), argues to the same effect in this proceeding. Petitioner argues that the transfer was not a prohibited - 7 - transaction under section 4975(a). According to petitioner, the prohibited transaction rules do not…
  10. 79 FR 26838 — Tax Treatment of Qualified Retirement Plan Payment of Accident or Health Insurance Premiums
    IRCFinal Rules (FR)May 12, 2014
    …s incurred by the employee, the employee's spouse, the employee's dependents (as defined in section 152 determined without regard to section 152(b)(1), (b)(2), or (d)(1)(B)), or any child (as defined in section 152(f)(1)) of the employee who as of the end of the taxable year has not attained age 27. * * * For the treat…
  11. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…
  12. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    IRCCourt RulingsMay 23, 2005related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2001, the taxable year in issue. All monetary amounts are rounded to the nearest dollar. T.C. Summary Opinion 2005-62 UNITED STATES TAX COURT THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v . COMMISS…
  13. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    …e 41628) As shown in Table 10, total costs for service providers and plan sponsors add up to about $152.5 million for the year 2011. Table 10—Total Discounted Costs of Proposal Year Cost of legal review Cost of general information disclosure Cost of investment information disclosure Cost of qualifying for exemption Tot…
  14. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    s not contend that decedent constructively received the sum in question in 1965. In Commissioner v. Smith, 324 U.S. 177, 181 (1945), the Court stated: Section 22(a) ol tlie Revenue Act [the predecessor of sec. 61, I.R.O. 1954] is broad enough to include in taxable income any economic or financial benefit conferred on t…
  15. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    nd nondeferred compensation must be subject to the reasonable allowance standards set forth in section 162(a)(1). Sec. 1.404(a)-1(b), Income Tax Regs. Petitioners contend that if Congress intended section 404(a) to be subject to reasonable compensation standards, it would have specifically mentioned section 162(a)(1). …
  16. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998related by meaning
    eafter received his SPB monthly. Petitioner retains a valid chief engineer’s license issued by the U.S. Coast Guard for standby use if needed by MEBA. On August 22, 1991, petitioner elected to forgo continued health care coverage through MEBA Medical. Petitioner checked option one and signed the election form discussed…
  17. 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…
  18. Rev. Rul. 2005-72 — 2006 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2006 are provided for use in …
    IRCRevenue RulingsNov 14, 2005related by meaning
    Form W-4, Employee's Withholding Allowance Certificate. The rules are effective with respect to wages paid on or after January 1, 2006. Notice 2005-85 2006 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OA…
  19. REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R…
    IRCProposed Rules (FR)Proposed Sep 24, 2007
    … 125(d)(2)(D)). (4) Dependent. The term dependent generally means a dependent as defined in section 152. However, the definition of dependent is modified to conform with the underlying Code section for the qualified benefit. For example, for purposes of a benefit under section 105, the term dependent means a dependent …
  20. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    OFFICE OF CHIEF COUNSEL DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 January 31, 2001 Number: 200118016 Release Date: 5/4/2001 WTA-D-126830-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Ce…