115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
…connected with providing for the payment of health care benefits
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4
The costs for 1992 ($1,853,529) were paid first from investment income for that year.
5
The parties stipulated that the Trust’s account limit for
1991, as defined in sec. 419A(c), was $65,652,991. However, that
stipulation is contrary to the recor…
IRCCode / StatuteJan 6, 2025
…alified higher education expenses" means qualified higher education expenses (as defined in section 529(e)(3)) for education furnished to— at an eligible educational institution (as defined in section 529(e)(5)).
(t)(7)(A)(i) (i) the taxpayer,
(t)(7)(A)(ii) (ii) the taxpayer's spouse, or
IRCCourt RulingsApr 16, 2020
…"qualified higher education expenses" means qualified higher
education expenses (as defined in sec. 529(e)(3)) for education furnished to the
taxpayer, the taxpayer's spouse, or any child (as defined in sec. 152(f)(1)) or
grandchild of the taxpayer or the taxpayer's spouse, at an eligible educational
institution (as de…
IRCCourt RulingsApr 13, 2010related by meaning
drawal . In a notice of deficiency,
respondent determined, inter alia, that the $52,132 .27
distribution from the IRA is includable in income and that petitioners are liable for the 10-percent additional tax on the
early distribution pursuant to section 72(t) .
Discussion
In general, the Commissioner's determination as…
IRCCourt RulingsAug 13, 1990
…t and that a decision may be rendered as a matter of law.” See Naftel v. Commissioner, 85 T.C. 527, 529 (1985); Jacklin v. Commissioner, 79 T.C. 340, 341 (1982); Espinoza v. Commissioner, 78 T.C. 412, 416 (1982). The moving party bears the burden of proving that there is no genuine issue of material fact and that such …
IRCCourt RulingsSep 28, 2016
…a QTP is includible in the distributee's gross
income in the manner provided under section 72. Sec. 529(c)(3)(A). A taxpayer
who receives a QTP distribution is subject to a 10% additional tax where the
distributions were not used for educational expenses. Secs. 529(c)(6),
530(d)(4)(A). Because there is no reliable evid…
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018related by meaning
…, books, supplies, equipment, and, in limited
circumstances, room and board. See secs. 72(t)(7)(A), 529(e)(3).
Mr. Dasent suggested at trial that petitioners qualify for this exception
because they used his IRA distributions to pay for their daughter's tuition to WCU
(...continued)
bound to accept a taxpayer's self-ser…
IRCCourt RulingsJun 9, 2009
…t required for the enrollment o
r
11
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attendance at an eligible educational i
72(t) (7) (A) , 529(e)(3) .
Petitioner contends that he paid e
children's college education and theref
section 72(t) exception for at least pa
However, petitioner did not introduce a
uncorroborated testimony regarding any
he allegedly m…
IRCCourt RulingsSep 17, 2009
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higher education expenses defined under section 72 ( t)(7), which"
in turn incorporates section 529 ( e) . Respondent argues that
transportation costs are not included in the definitions of
qualified expenses in section 72(t)(7 ) or 529 ( e)(3) and, in an y
event, petitioner has not proven the amount of transportat…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-7 Rev. Rul. 2006-7
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2006.
T.D. 9238 T.D. 9238
Temporary and proposed regul…
IRCCourt RulingsAug 4, 2005
… and equipment required for enrollment or attendance at
an eligible educational institution.
5
Sec. 529(e)(3)(A). Room
and board may be qualified higher education expenses for students
under guaranteed plans who are at least half-time students. Sec.
529(e)(3)(B). Furthermore, higher education expenses must be for
the e…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsAug 22, 2002
…axpayer’s spouse or child,
among others, at an eligible educational institution. Secs.
72(t)(7)(A), 529(e)(3)(A). Under some circumstances, qualified
higher education expenses also may include the costs of room and
board. However, in the present case petitioner has failed to
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show that she satisfied the statutory …
IRCCourt RulingsFeb 22, 1978related by meaning
he income of the fund from taxation, and the more severe sanction is to tax the contributor on the excess contributions when distributed to him. Conf. Rept. 93-1280 at 501-502; H. Rept. 93-807 at 363-366; S. Rept. 93-383 at 211-213.
Some writers have suggested that these sanctions are unduly harsh (see J. Hall, T. Dobs…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
2. Section 300.4 is amended by revising paragraphs (b) and (d) to read as follows:
§300.4 Enrolled agent special enrollment examination fee.
* * * * * (b) Fee. The fee for taking the enrolled agent special enrollment examination is $66 per part, which is the cost to the government for overseeing the development and adm…
IRCCourt RulingsFeb 3, 2016related by meaning
"forfeited to a bank, mutual savings bank, savings and loan association,
building and loan association, cooperative bank or homestead association as a penalty for premature withdrawal of funds from a time savings account, certificate
4At trial Martin conceded on the record that he was liable for the sec. 72(t)
addition…
IRCProposed Rules (FR)Proposed Jan 13, 2025related by meaning
end paper submissions to: CC:PA:01:PR (REG-101268-24), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations, call Jessica S. Weinberger at (202) 317-6349 or Jason E. Levine at (202) 317-4117; concerning submi…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
IRCCourt RulingsNov 25, 2002related by meaning
(c)(2).
Thus, we sustain respondent’s determination on this issue.
C. Petitioner’s IRA Deductions
As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the
burden of proving his or her entitlement to the claimed
deductions.
18
Rule 142(a)(1); see New Colonial …