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41. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    T.C. Memo. 1996-337 UNITED STATES TAX COURT PARKER-HANNIFIN CORPORATION, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22121-93. Filed July 24, 1996. William R. Stewart , Kent L. Mann , Karen E. Rubin , Stephen F. Gladstone , and Dena M. Kobasic , for petitioner. Elsie Hall , Randall P. Andreoz…
42. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    … B in a complete liquidation. Under § 1.1502-34, section 332 applies to both S and B. Under section 337, X has no gain or loss from its liquidating distribution to S. Under sections 336 and 337(c), X has a $40 gain from its liquidating distribution to B. B has a $40 basis under section 334(a) in the assets received fro…
43. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
44. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
45. PLR 200109010 — Sale/Exchange
    IRCPrivate Letter RulingsMar 2, 2001related by meaning
    n believes a court would find section 4975 to be punitive in nature and, therefore, considered a penalty under the Bankruptcy Code. See , e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful cond…
46. ERISA § 4068(c) (29 U.S.C. § 1368) — Lien for liability
    PBGCCode / StatuteJan 6, 2017related by meaning
    (c) (c) Priority (c)(1) (1) Except as otherwise provided under this section, the priority of a lien imposed under subsection (a) shall be determined in the same manner as under section 6323 of title 26 (as in effect on April 7, 1986). Such section 6323 shall be applied for purposes of this section by disregarding subse…
47. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
48. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    l Systems, Inc., 586 F.2d 1036, 1039 (5th Cir. 1978); In re Kline, 403 F. Supp. 974, 979 (D. Md. 1975), affd. per curiam 547 F.2d 823 (4th Cir. 1977). This Court’s jurisdiction is limited to redetermining the amount of a deficiency or addition to tax determined by the Commissioner. Sec. 6213. For such reason, we genera…
49. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    PBGCRegulationsJan 1, 2017
    …t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
50. 78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements
    ERISAFinal Rules (FR)Mar 1, 2013related by meaning
    onstitution, the Secretary will generally obtain judicial authorization before issuing a summary seizure order. (See Colonnade Catering Corp. v. U.S., 397 U.S. 72 (1970): “Where Congress has authorized inspection but made no rules governing the procedures that inspectors must follow, the Fourth Amendment and its variou…
51. 29 C.F.R. § 4000.41 — What are these computation-of-time rules about?
    PBGCRegulationsJan 22, 2018
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
52. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    or lack of jurisdiction. Appropriate orders will be issued. Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
53. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000related by meaning
    994 and 1995 tax liabilities. We grant respondent's motion for a penalty under section 6673. Under section 6673, this Court may award a penalty to the United States of up to $25,000 when the proceeding has been instituted or maintained by the taxpayer primarily for delay or if the taxpayer's position in such proceeding…
54. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    … a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information. 3  Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here: https://www.bls.gov/​news.release/​pdf/​jolts.pd…
55. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    ension, profit-sharing, or annuity plan, or other plan deferring the receipt of compensation, subsection (a) shall apply as if there were such a plan. “Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary shall prescribe a…
56. Circular 230 § 10.71(b) — Discovery.
    Joint BoardRegulationsDec 30, 2016related by meaning
    (b) (b) Depositions upon oral examination (b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters. (b)(2) (2) In ordering a depos…
57. 96 T.C. 644; 96 T.C. No. 24 — O'Malley v. Commissioner
    IRCCourt RulingsApr 15, 1991related by meaning
    outheast & Southwest Areas Pension Fund v. Central Transport, Inc., 472 U.S. 559, 570 (1985); Donovan v. Mazzola, 716 F.2d 1226, 1231 (9th Cir. 1983). The basis for the liability of a disqualified person for the excise tax under section 4975(a) and (b), i.e., participation, is not the same as the basis for liability of…
58. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
59. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    IRCCourt RulingsMay 28, 2003related by meaning
    r the Northern District of Illinois, in which petitioner pleaded guilty to one count of obstructing and impeding the due administration of the Code in violation of section 7212(a). 3 - 6 - 3 (...continued) corruptly or by force or threats of force (including any threatening letter or communication) endeavors to intimid…
60. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…