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79 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2011-64 — Larry Ray & Marjorie Z. Zedaker v. Commissioner
    IRCCourt RulingsJun 1, 2011
    …); Woods v. Commissioner, 92 T.C. 776, 784-787 (1989); Estate of Rosenberg v. Commissioner, 73 T.C. 1014, 10171018 (1980); Hays Corp. v. Commi-ssioner, 40 T.C. 436, 442-443 (1963), affd. 331 F.2d 422 (7th Cir. 1964) In other words, absent some constitutional defect, we are constrained to apply ' the law as written, see…
  2. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  3. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  4. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985
    …64); Gegax v. Commissioner, 73 T.C. 329, 334 (1979). Compare Smith v. United States, 460 F.2d 1005, 1014-1015 (6th Cir. 1972).
  5. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007
    …eradventure that the income tax on wages is constitutional") ; United States v . Romero , 640 F .2d 1014, 1016 (9th Cir . 1981) (compensation for labor or services, paid in the form of wages or salary, has been universally held by the courts of this republic to be income, subject to the income tax laws currently applic…
  6. Treas. Reg. § 1.72-17(b)(3) — Special rules applicable to owner-employees.
    IRCRegulationsJul 26, 2016related by meaning
    (b)(3) (3) Any amounts to which this paragraph applies and which are not includible in gross income under the rules of subparagraph (2) of this paragraph shall be subject to the provisions of section 72(e) and § 1.72-11. However, for taxable years beginning before January 1, 1964, section 72(e)(3), as in effect before …
  7. 81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    75(e)(1) of the Code are included within the scope of relief provided by PTE 75-1 because it was issued jointly by the Department and the Service. See PTE 2002-13, 67 FR 9483 (March 1, 2002) (preamble discussion). For simplicity and consistency with the other new exemptions and amendments to other existing exemptions p…
  8. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    … have already illustrated that a hypothetical buyer would not take into account the tax ¹³See secs. 1014, 408A. - 34 - consequences of distributing the assets in the IRAs because the buyer would be purchasing the securities, not the IRAs themselves. Unlike the other cases the estate has cited, the tax liability associa…
  9. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  10. T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations …
    IRCTreasury DecisionsAug 6, 2007related by meaning
    blic hearing on the proposed regulations is scheduled for October 24, 2007. Rev. Rul. 2001-48 and Notice 2006-43 modified. REG-138707-06 REG-138707-06 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
  11. T.C. Memo. 2010-115 — Jerry L. Keenan & Cynthia S. Keenan v. Commissioner
    IRCCourt RulingsMay 3, 2018
    … in part, vacating in part 108 T.C. 344 (1997); see also DJB Holding Corp.v. Commissioner, 803 F.3d 1014, 1030-1031 (9th Cir. 2015), affg W_B Acquistion, Inc. v. Commissioner, T.C. Memo. 2011-36; Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43, 99 (2000), af[d, 299 F.3d 221 (3d Cir. 2002). Petitioner testified t…
  12. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  13. 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 …
  14. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  15. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  16. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979
    …162(a). Petitioner argues, citing principally In Re Ferrall’s Estate, 41 Cal.2d 166, 258 P.2d 1009, 1014-1015 (1953), that Citrus did not retain dominion and control over the trust assets since the California courts will interpose their judicial discretion where a trustee does not act in a manner contemplated by the se…
  17. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984
    …ering the trust discriminatory in operation. Pulver Roofing Co. v. Commissioner, 70 T.C. 1001, 1008-1014 (1978). We do not think petitioner can avoid the consequences resulting from the trust’s discriminatory contributions by asserting "unforeseen circumstances” as the cause thereof.
  18. 45 T.C. 168 — Lilly v. Commissioner
    IRCCourt RulingsNov 26, 1965related by meaning
    ired employee of the Civil Service Retirement Act, see Edward C. Heard, 40 T.C. 7, affd. 326 F. 2d 962 (C.A. 8, 1964), certiorari denied 377 U.S. 378. For reasons which will later appear, we need not take too seriously petitioner’s contention that the entire amount of $1,024.92 received during each of the taxable years…
  19. 76 T.C. 499; 2 Employee Benefits Cas. (BNA) 1145 — Fujinon Optical, Inc. v. Commissioner
    IRCCourt RulingsMar 31, 1981
    …in various coverage situations. See, for example, Pulver Roofing Co. v. Commissioner, supra at 1013-1014; John Duguid & Sons, Inc. v. United States, 278 F. Supp. 101, 104 (N.D. N.Y. 1967). Section 1.401-l(b)(3), Income Tax Regs., provides, in part, that—
  20. 80 FR 22004 — Proposed Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Em…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    to Citation 11.   See Preamble to PTE 75-1, Part V, 40 FR 50845 (Oct. 31, 1975); ERISA Advisory Opinion 86-12A (March 19, 1986). Back to Citation 12.  Because of this limitation, the Department views it as unnecessary to condition this exemption on the fiduciary's adherence to the impartial conduct standards, including…