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77 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  2. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …15 65– 66 ( same where taxpayer’s IRA was subject to a civil forfeiture to USA ) , aff’d , 166 F.3d 1201 (2d Cir. 1998) (unpublished table decision) ; Santilli v. Commissioner, T.C. Memo. 1995-278, 69 T.C.M. (CCH) 2974 , 2975 6 [* 6 ] (holding that taxpayer had dominion and control over interest i ncome from interest-b…
  3. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    distribution , respondent determined a 10% additional tax under section 72(t) . In response to each notice, p etitioner timely petitioned this Court , and we consolidated these cases for trial, briefing , and opinion . Before trial p etitioner filed a Pretrial Memorandum , in which he advanced frivolous arguments. He a…
  4. 79 FR 35942 — Ninety-Day Waiting Period Limitation
    IRCFinal Rules (FR)Jun 25, 2014
    …00, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services reg…
  5. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002
    …Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpayer's plea agreement, all funds on deposit in several - 4 …
  6. 79 FR 26192 — Health Care Continuation Coverage
    ERISAProposed Rules (FR)Proposed May 7, 2014
    …5-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Pub. L. 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Pub. L. 111-148, 124 Stat. 119, as amended by Pub. L. 111-152, 124 Stat. 1029; Secretary of Labor's Order 1-2011, 77 FR 1088 (January 9, 2012). List of Subjects in 29 CFR Part 2590 Continuation coverag…
  7. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002
    …ject to the section 72(t) additional tax), affd. without published opinion on other issues 166 F.3d 1201 (2d Cir. 1998). Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent .
  8. T.C. Memo. 2000-246 — Eugene W. Alpern v. Commissioner
    IRCCourt RulingsAug 8, 2000
    …y is governed by local law. See Lee v. Commissioner , 64 T.C. 552 (1975), affd. per curiam 550 F.2d 1201 (9th Cir. 1977). Consequently, we decline to disregard the divorce judgment or treat it as a nullity. In this case, petitioner merely alleges that the divorce was not final and has introduced no evidence to support …
  9. 29 C.F.R. § 2570.115 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
  10. T.C. Summary Opinion 2003-45 — Nick Allan Palermino v. Commissioner
    IRCCourt RulingsApr 28, 2003
    … decision in Murillo v. Commissioner , T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), and no longer assesses the 10-percent addition to tax under sec. 72(t). See also Larotonda v. Commissioner , 89 T.C. 287 (1987). 1998 Federal income tax. The issue is whether a distribution from peti…
  11. Notice 2011-2 — This notice provides guidance on the application of section 162(m)(6) of the Code. Section 162(m)(6) limits the allowable deduction for remuneration for servic…
    IRCNoticesJan 10, 2011related by meaning
    axable year to which deferred deduction remuneration is attributable in the case of a corporate event such as a merger, acquisition or reorganization. Comments may be submitted through March 23, 2011 to Internal Revenue Service, CC:PA:LPD:RU (Notice 2011-02), Room 5203, PO Box 7604, Ben Franklin Station, Washington DC …
  12. 79 FR 10320 — Ninety-Day Waiting Period Limitation
    IRCProposed Rules (FR)Proposed Feb 24, 2014
    …00, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services reg…
  13. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004
    …743 F.2d 781, 795 (11th Cir. 1984); Young v. Commissioner , 83 T.C. 831, 841 (1984), affd. 783 F.2d 1201 (5th Cir. 1986). As we stated in Dunavant v. Commissioner , 63 T.C. 316, 320 (1974): “We are not at liberty to infer that an election existed when the unequivocal proof required by Congress does not exist.” Petition…
  14. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    ief because respondent has not determined a deficiency for any of the years at issue . Petitioner filed a notice of objection to respondent's motion . In the Tax Relief and Health Care Act of 2006, Pub . L . 109432, div . C, sec . 408(a), (c), 120 Stat . 3061, 3062 (TRHCA section 408), Congress amended section 6015(e) …
  15. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    Judicial Notice Motions. - 4 - Rule 201(f) of the Federal Rules of Evidence provides that judicial notice may be taken at any stage of the proceeding. Petitioner's Judicial Notice Motions will be denied in this case, however, because their many paragraphs constitute nothing more than a hodgepodge of argument and statem…
  16. DOL Office of Administrative Law Judges — USDOL v. COMPGRAPHIX, INC
    ERISACourt RulingsOct 14, 1999
    …beneficiaries . . . " [citing Sutton v. Weirton Steel Div. Of Nat'l Steel Corp., 567 F. Supp. 1184, 1201 (N.D.W. Va.), aff'd 724 F.2d 406 (4th Cir. 1983)]. Without an independent audit, it is impossible to ascertain whether there were fiduciary breeches in the administration of Plan 001. Questions remain such as what b…
  17. 29 C.F.R. § 2570.136 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
  18. 78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Jul 2, 2013
    …00, 112 Stat. 645 (42 U.S.C. 651 note); sec. 512(d), Public Law 110-343, 122 Stat. 3881; sec. 1001, 1201, and 1562(e), Public Law 111-148, 124 Stat. 119, as amended by Public Law 111-152, 124 Stat. 1029; Secretary of Labor's Order 3-2010, 75 FR 55354 (September 10, 2010). The Department of Health and Human Services reg…
  19. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  20. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    letter and the examination report allows B to compute the specific amount of the liability attributable to the adjustment to the ( printed page 52263) partnership item and the basis for that adjustment and therefore satisfies the notice requirement of paragraph (a). Because the IRS provided that notice to the TMP, B's …