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41. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    he Federal Government generally constitute gross income unless excluded by law. Schuller v. Commissioner, T.C. Memo. 2012-347; sec. 1.61-11(a), Income Tax Regs. For a taxpayer who uses the cash receipts and disbursements method of 7 Petitioner's assertion was tried by the consent of the parties. See Rule 41(b). - 7 - a…
42. 42 T.C. 299 — Sherwood Swan & Co. v. Commissioner
    IRCCourt RulingsApr 30, 1964related by meaning
    oyment is for not more than 20 hours in any. one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
43. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
44. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
    IRCCourt RulingsJun 4, 1984related by meaning
    )(2), ERISA, a civil action for relief under section 409, ERISA, may be brought by the Secretary of Labor, by a plan participant, or by a beneficiary. Title II of ERISA contains amendments to the Internal Revenue Code relating to retirement plans. Prior to ERISA, a qualified plan could become disqualified if the trust …
45. 41 T.C. 685 — Conroy v. Commissioner
    IRCCourt RulingsFeb 26, 1964related by meaning
    kly pay period, the Secretary or his delegate shall by regulations prescribe the method of determining the weekly rate at which such amounts are paid. (e) Accident and Health Plans. — For purposes of this section and section 104— (1) amounts received under an accident or health plan for employees, and (2) amounts recei…
46. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004related by meaning
    or his own advantage information which he may have personally or professionally * * *" S. Rept. 91-552, 29, 30-31 (1969), 1969-3 C.B. 443, 444. To the same effect, see also TRA '69 Blue Book 31, 32. c. Sec. 4975 (ERISA '74) By 1974, the Congress reached similar conclusions about the same sorts of transactions involving…
47. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
48. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
49. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    s and provisions contained in the Employee Retirement Income Security Act of 1974 are not applicable. Jim’s Window Service, Inc., T.C. Memo, 1974-115. See also Jim’s Window Service, Inc., supra; Roger K. Haugen, T.C. Memo. 1971-294; Robert H. Cowing T.C. Memo. 1969-135. See also Claremont Country Club v. I.A.C., 174 Ca…
50. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    se cases. To the contrary, petitioners' supplement informs the Court that "[p]etitioners agree with Respondent that the arrangements were entered into after September 17, 2003", for purposes of sec. 1.61-22, Income Tax Regs. Petitioners in their opening brief now invite the Court to decide whether the life insurance ar…
51. 72 T.C. 768; 1 Employee Benefits Cas. (BNA) 1603 — Guest v. Commissioner
    IRCCourt RulingsAug 3, 1979related by meaning
    155. Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77. Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue. Respondent concedes …