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41. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    ty of any of the foregoing.” Since the relevant portions of secs. 219 and 220 during the years at issue are identical, we wilt refer only to sec. 219. The parties have stipulated that the IRA’s in issue are of a type described in sec. 408(a), a necessary element for the deduction of contributions thereto, and that Mrs.…
42. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
43. Treas. Reg. § 1.401(l)-4(e)(3)(iii)(B) — Special rules for railroad plans.
    IRCRegulationsMay 18, 2016
    …nce (percent) 65 0.523 64 0.485 63 0.448 62 0.420 61 0.392 60 0.378 59 0.364 58 0.350 57 0.336 56 0.322 55 0.295 Table III[Social security retirement age 65] Age at which benefits commence Annual factor in maximum excess allowance and maximum offset allowance (percent) 64 0.523 63 0.485 62 0.448 61 0.418 60 0.388 59 0.…
44. T.C. Summary Opinion 2003-153 — Joseph Jones v. Commissioner
    IRCCourt RulingsOct 20, 2003related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 1999, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Summary Opinion 2003-153 UNITED STATES TAX COURT JOSEPH JONES, Petitioner v . COMMISSIONER OF…
45. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …ds'on the application of common law concepts. See Nationwide Mut. Ins. Co. v. Darden, 503 U.S. 318, 322-323 (1992); Weber v. Coèmissioner, 103 T.C. 378, 386 (1994),
46. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    Tannenwald, Judge: Respondent determined deficiencies in the Federal income tax of petitioner for 1971, 1972, and 1973 in the respective amounts of $3,576.58, $4,052.04, and $3,912 together with negligence penalties under section 6653(a). The negligence penalties have been conceded by respondent, and capital loss adjus…
47. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    …ts expected to be made during the first 5 years, using the first segment interest rate of 5.07%; $5,322.26, which is the present value of payments expected to be made during the next 15 years, using the second segment interest rate of 6.09%; and $183.54, which is the present value of payments expected to be made after …
48. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
49. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
50. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
51. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … 2550.404a-1)); Laborers Nat'l Pension Fund. v. N. Trust Quantitative Advisors, Inc., 173 F.3d 313, 322 (5th Cir. 1999) (“Since 1979, investment managers have been held to the standard of prudence of the modern portfolio theory by the Secretary's regulations.” (citing 29 CFR 2550.404a-1)). Back to Citation 40.   See, e…
52. 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’ …
53. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998related by meaning
    s in which taxpayers have sought to avoid the 10-percent additional tax under section 72(t). We repeatedly have ruled that we are bound by the list of statutory exceptions to section 72(t) contained in section 72(t)(2)(A). See, e.g., Clark v. Commissioner , 101 T.C. 215, 224-225 (1993); Vorwald v. Commissioner , T.C. M…
54. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
55. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    OPINION COHEN, Judge: Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
56. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    tion that petitioners are liable for the 10-percent additional tax imposed by section 72(t). Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of Additional Tax.--If an…
57. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
58. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
59. T.C. Summary Opinion 2006-50 — Robert E. & Lori K. Reichner v. Commissioner
    IRCCourt RulingsApr 11, 2006
    … income of the receiving spouse . Sec . 1041 ; Estate of Goldman v . Commissioner , 112 T .C . 317, 322 (1999), affd . without published opinion sub nom . Schutter V . Commissioner , 242 F .3d 390 (10th Cir . 2000) . On the other hand,
60. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    ERISACourt RulingsAug 31, 2026
    …ife Ins. Co. of N. Am. v. Ortiz , 535 F.3d 990, 994 (9th Cir. 2008) (citing Cook v. Cook , 111 P.2d 322, 328 (Cal. 1941)). T hus , where the beneficiary takes “every reasonable effort under the circumstances, complying as far as [s]he is able with the rules” and there is a “clear manifestation of intent” to make a chan…