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69 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  2. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    t it was final and conclusive and not to be reopened except “upon a showing of fraud or malfeasance or a wilful misrepresentation of a material fact.” In view of the foregoing we conclude that the separate identity of the petitioner and the other two corporations must be recognized in these rebate proceedings. Section …
  3. 105 T.C. 29; 105 T.C. No. 3 — Rodoni v. Commissioner
    IRCCourt RulingsJul 24, 1995
    …substance or essence of the statute, they must be rigidly observed. Taylor v. Commissioner, 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner, 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather are give…
  4. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    Panuthos, Special Trial Judge: This case was heard pursuant to the provisions of section 7456(d) of the Code. Respondent determined a deficiency of $474.10 in petitioner’s 1981 Federal income tax. The issue for decision is whether petitioner is entitled to a deduction of $1,500 for a contribution to an Individual Retir…
  5. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … Secretaries and Administrative Assistants 43-6013 27.94 18.13 46.07 Human Resources Specialists 13-1071 49.09 42.74 91.83 Business Operations Specialist 13-1198 59.60 41.72 101.32 General and Operations Manager 11-1021 88.25 34.30 122.55 Compensation and Benefits Manager 11-3111 96.97 24.81 121.78 Computer and Informa…
  6. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…
  7. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    that contributions are deductible if the pension does not exceed the maximum current threshold, which was the equivalent of e1372.72 (euros) in 2001. The second document is an undated letter to petitioner from Union Mutualistic Retraite (UMR) responding to her request dated July 11, 2003, to change her contributions. …
  8. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    … Secretaries and Administrative Assistants 43-6013 18.75 18.75 37.50 Human Resources Specialists 13-1071 33.38 33.38 66.76 Business Operations Specialist 13-1198 38.57 38.57 77.14 General and Operations Manager 11-1021 59.15 59.15 118.30 Compensation and Benefits Manager 11-3111
  9. 81 FR 92316 — Claims Procedure for Plans Providing Disability Benefits
    ERISAFinal Rules (FR)Dec 19, 2016
    …rator in the course of making his or her decision. See Miller v. United Welfare Fund, 72 F.3d 1066, 1071 (2d Cir.1995) (compiling cases and stating that “[m]ost circuits have declared that, in reviewing decisions of plan fiduciaries under the arbitrary and capricious standard, district courts may consider only the evid…
  10. Rev. Rul. 2003-85 — Excise tax; terminating defined benefit plan; reversion. This ruling describes the treatment of a transfer from a terminating defined benefit plan to a defined…
    IRCRevenue RulingsAug 11, 2003related by meaning
    e $40X that the employer receives is subject to the 20 percent excise tax under § 4980(a) and is includible in income under § 61. DRAFTING INFORMATION The principal drafters of this revenue ruling are Steven Linder of the Employee Plans, Tax Exempt and Government Entities Division and Vernon Carter of the Office of the…
  11. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. - 9 - 5 See also …
  12. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    eir RCP has changed since the time of the settlement officer's determination because of their middle son's death. 1. Collection Alternatives Generally During the course of a section 6330 hearing taxpayers may propose collection alternatives such as an OIC or an installment agreement. Sec. 6330(c)(2)(A)(iii); Giamelli v…
  13. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    tment of section 30D(g) (that is, August 16, 2022) pursuant to section 104 of the Federally Recognized Indian Tribe List Act of 1994 (25 U.S.C. 5131). Section 30D(g)(10) provides that in the case of any taxpayer who has made a credit transfer election with respect to a new clean vehicle and received a payment from an e…
  14. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
  15. 41 T.C. 685 — Conroy v. Commissioner
    IRCCourt RulingsFeb 26, 1964related by meaning
    It follows, therefore, that the amounts received by petitioners from the special fund are not excludable from gross income under either section 104 or section 105 unless they are covered by subsection 105(b), subsection 105(c), or subsection 105(d). Only the last subsection (105(d)), to which petitioners make no refere…
  16. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  17. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    as provided in paragraphs (3) and (4), paragraph (1) shall not apply to any of the following distributions: (A) In general.--Distributions which are-- (i) made on or after the date on which the employee attains age 59 1/2, (ii) made to a beneficiary (or to the estate of the employee) on or after the death (continued...…
  18. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    so. Despite the fact that Mrs. Colombell received no tax benefit whatsoever from her “participation” in Inova’s retirement plan, the Court is not free to rewrite the law. See, e.g., Hildebrand v. Commissioner , 683 F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v. Commissioner , 661 F.2d 53, 54-55 (5th …
  19. T.D. 9142 — REG-101447-04 Final regulations under section 408(q) of the Code provide requirements relating to deemed IRAs that may be included in qualified employer plans,…
    IRCTreasury DecisionsAug 23, 2004related by meaning
    h the requirements of section 408. The temporary amendment also provides special rules regarding the application of §1.408-2(e) to governmental units. E. Other Comments Other comments included one noting that the proposed regulations require that the plan document of the qualified employer plan must contain the deemed …
  20. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    tions in his gross income for 1995. The only exception to section 408(d)(1) that might apply in the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The transfer of an individual's interest in an individual retirement account or an individual retirement annuity to his spo…