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83 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …ice and for each plan, insurance policy, or coverage included in an aggregated Allowed Amount File.[154] The Departments finalized this requirement in the 2020 final rules because if the threshold were applied to the aggregated claims data at the service provider level, rather than for each plan or coverage as is requi…
  2. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …O REVENUE PROCEDURE 2017–4? 153 .01 In general 153 .02 Changes related to pre-approved plan program 154 .03 Changes to fees for EP VCP Submissions 154 .04 Changes to other fees 155 .05 Other changes 155 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGRE…
  3. T.C. Memo. 2012-44 — James Anthony Fonteneaux, Sr. v. Commissioner
    IRCCourt RulingsFeb 21, 2012related by meaning
    Respondent prepared decisiori.documents reflecting respolident's concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and . sanctions against respondent based on "reckless professional behavior." Petitioner is frustr…
  4. Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl…
    IRCRevenue RulingsMar 8, 2004
    Rul. 66-110, as amplified by Rev. Rul. 67-154, for periods after December 31, 2003, with respect to arrangements entered into after January 28, 2002. Rev. Rul. 2003-105, 2003-40 I.R.B. 696, obsoleted Rev. Rul. 66-110 for arrangements entered into after September 17, 2003, except as provided in paragraph 3 of Section I…
  5. 68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner
    IRCCourt RulingsSep 12, 1977related by meaning
    r, 68 T.C. 826 (1977). In view of concessions made by the parties and our conclusions on the disputed issues, Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated. Variances between this schedule and Form 4848 reflect persons …
  6. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    IRCCourt RulingsSep 24, 2026
    … Examination Division ’ s determination to assert a penalty. See Belair Woods, LLC v. Commissioner, 154 T.C. 1, 15 (2020) . Petitioner does not dispute that the IRS met these requirements here. The IRS secured managerial approval of the penalty on May 20 , 202 4, when the revenue agent’s manager noted in the examinatio…
  7. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …e the vesting protections applicable to the VTTM. See Concerned Dublin Citizens v. City of Dublin , 154 Cal. Rptr. 3d 682, 698 (Ct. App. 2013) (holding that new threshold requirements for greenhouse gases were not new information requiring a supplemental environmental impact report because the potential environmental i…
  8. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    an were part of a split-dollar life insurance arrangement. We hold they were; 3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's income in a single, corporate-level proceeding. However, the Small Business Job Protection Act…
  9. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …tate law. See Belk v. Commissioner, 140 T.C. 1, 13 n.21 (2013) , supplemented by T . C. Memo. 2013- 154, aff’d , 774 F.3d 221 (4th Cir. 2014). In Alabama judicial review of an unambiguous contract is limited to the four corners of the document. See Lafayette Land Acquisitions II, LLC v. Walls, 385 So. 3d 519, 522– 23 (…
  10. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ing plan. Held, such transfer is an employer reversion subject to the 10-percent excise tax under sec. 4980, I.R.C. Robert L. Raymond, for petitioner. P. Joseph Ineich, for respondent. *54 Hamblen, Chief Judge. HAMBLEN *189 OPINION Hamblen, Chief Judge: This case was assigned to Special Trial Judge Francis J. Cantrel p…
  11. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
  12. T.C. Summary Opinion 2008-32 — David K. Carlson v. Commissioner
    IRCCourt RulingsMar 31, 2008
    … circumstances . Geftman v . Commissioner , T .C . Memo . 1996-447, revd . in part on other grounds 154 F .3d 61 (3d Cir . 1998) . The ultimate question remains whether "there [was] a genuine intention to create a debt, with a reasonable
  13. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    1 All section references are to the Internal Revenue Code as amended, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-159 UNITED STATES TAX COURT ROBERT CHARLES FOHRMEISTER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11748…
  14. 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 …
  15. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    t acquire a beneficial ownership interest in the ETS trust contributions in 1974. Because of a concession by respondent with respect to the year 1973, Decision will be entered under Rule 155. Reviewed by the Court. Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1954 as amended …
  16. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003
    … F.3d 1435, 1439-1442 (Fed. Cir. 1996), and Truck & Equip. Corp. v. Commissioner , 98 T.C. 141, 145-154 (1992). We stress that the House Committee on Ways and Means, in describing a 1984 amendment to sec. 404(b), stated that: Generally, all compensation arrangements which defer receipt of compensation by the employee o…
  17. PLR 201351020 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsDec 20, 2013
    …d States , 173 Ct. Cl. 139, 351 F.2d 619 (1965); and Estate of S cofield v. Commissioner , 266 F.2d 154, 159 (6th Cir. 1959), revg. 25 T.C. 774 (1956). CONCLUSION: PLR - 113782-13 11 Taxpayer is allowed a loss under section 165 relating to the to the surrender of BOLI Policies 1, 2, and 3, with the amount of such loss …
  18. 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…
  19. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …p’x at 152–53. He was “present for all of the negotiations up through the ’93 negotiations.” Id. at 154. Porter affirmed, under oath, that during the 1993 negotiations, he “believe[d] the state of the law was we couldn’t touch” the healthcare benefits of a former employee who had retired prior to the 1993 negotiations. As…
  20. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    4 (1984); see United States v. Mead Corp., 533 U.S. 218 (2001). Although they may be entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not decide whether Notice 2004-8, supra, should be given Skidmore deference because the Transaction does not féll…