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41. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …l DWB's (number) 0 6 50 57 87 56 256 Withdrawal dist. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4,789,467 30,420,770 B. Suspense Account transactions
42. 29 C.F.R. § 2520.104-45 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
43. 29 C.F.R. § 4281.14-4281.15 — [Reserved]
    PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
44. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
45. T.C. Memo. 1996-267 — G. Richard & Sara B. Childs v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …rican Bank distributed and petitioner received the account balance of petitioner's IRA's, i.e., $97,227.74, on or about November 6, 1990. Distribution of the Fidelity IRA Petitioners were accustomed to dealing with Fidelity by telephone. On August 14, 1990, petitioner Richard Childs telephoned Fidelity and requested th…
46. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
47. 29 C.F.R. § 4907.131-4907.139 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
48. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …ong test for determining whether to afford an agency pronouncement Chevron deference . Id . a't 226-227 ("We hold that administrative implementation of a particular statutory provision qualifies for Chevron deference when it appears that Congress delegated authority to the agency generally to make rules carrying the fo…
49. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
50. 29 C.F.R. § 4907.104-4907.109 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
51. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963related by meaning
    422, 441. Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
52. PLR 201103002 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations
    IRCPrivate Letter RulingsJan 21, 2011
    …nsation that can be deferred under private plans." (H.R. Report No. 95-1445 at 53 and 59, 1978-3 CB 227 and 233). This indicates that a significant Congressional concern when it enacted section 457 was limiting the revenue loss that occurs when em ployees defer compensation that their tax - exempt employer is unable to…
53. 29 C.F.R. § 4907.112-4907.129 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
54. 29 C.F.R. § 4907.141-4907.148 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
55. 73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner
    IRCCourt RulingsOct 30, 1979related by meaning
    In addition, section 1.401(b)-1(e), Income Tax Regs., authorizes the Commissioner to further extend the remedial amendment period at his discretion. 7 *42 *188 This provision, upon which petitioner relies, confers discretionary authority on the Commissioner. When reviewing discretionary administrative acts, this Court …
56. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
57. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …ates indicated on his monthly invoices to the BCG. - 18 - questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg. a Memorandum Opinion of this Court; Weiss v. Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-467. The Court i…
58. T.C. Memo. 1996-212 — Louis R. & Gregoria S. Gomez v. Commissioner
    IRCCourt RulingsMay 1, 1996
    … a lump-sum payment to Louis R. Gomez from the Civil Service Retirement System in the amount of $52,227.53 in 1987 is includable in petitioners' gross income. Background All of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time the petition was filed…
59. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024
    … We round all monetary amounts to the nearest do llar. Served 06/17/24 2 [* 2 ] capital gain of $32,227 , t a xable payments of $6,236 from a medical
60. T.C. Memo. 1997-556 — A. C. Green Electrical Contractors, Inc. v. Commissioner
    IRCCourt RulingsDec 22, 1997
    …d Jakubowicz and their spouses, petitioner made contributions to the plans in the total amounts of $227,646, $226,794, and $226,794, respectively, for each of the years 1987, 1988, and 1989. On its Federal income tax returns for years ending September 30, 1987, 1988, and 1989, petitioner claimed deductions under sectio…