Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 84 T.C. 146 (not yet in the library — opens the official source)
76 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 54.9802-3T(e) — Additional requirements prohibiting discrimination based on genetic information (temporary).
    IRCRegulationsDec 30, 2016
    …tic test before the claim is paid. (ii) Conclusion. See Example 1 in 29 CFR 2590.702-1(e) or 45 CFR 146.122(e) for a conclusion under the rules of paragraph (c)(4) of 29 CFR 2590.702-1 or 45 CFR 146.122 similar to the rules of paragraph (c)(4) of this section that the issuer is permitted to request only the minimum amo…
  2. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTE…
  3. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  4. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  5. IRCCourt RulingsOct 12, 1978related by meaning
    other than that presented before the Internal Revenue Service and contained in the administrative record as so defined. * * * See also Rule 210(c)(4). Here, the petitioner timely filed his comment letter with the District Director in which he raised four specific "matters." As to such matters, he exhausted his administ…
  6. 83 FR 54420 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
    IRCProposed Rules (FR)Proposed Oct 29, 2018
    …insurance coverage, provided all the conditions in 29 CFR 2510.3-1(l) are satisfied. * * * * * PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET 17. The authority citation for part 146 continues to read as follows: Authority: 42 U.S.C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92…
  7. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    … certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually paid by him to Ada and (b)…
  8. 83 FR 38212 — Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Aug 3, 2018
    …s and their applicability to other people or circumstances shall continue in effect. * * * * * PART 146—REQUIREMENTS FOR THE GROUP HEALTH INSURANCE MARKET 9. The authority citation for part 146 is revised to read as follows: Authority: 42 U.S.C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92…
  9. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  10. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .
  11. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  12. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  13. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    C. 1005, 1011-1013 (1972), affirmed per order (C.A. 1, Apr. 26, 1973). Petitioners have not shown that BG timely paid the disputed funds to the trust. Petitioners urge us to expand or modify the terms “paid” or “payment,” holding that substantial compliance with the statute is sufficient in order to avoid denial of a d…
  14. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    T.C. Memo. 1998-203 UNITED STATES TAX COURT RAMON A. GARCIA AND BERTHA E. GARCIA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21532-95. Filed June 3, 1998. Richard M. Taylor and James E. McCutcheon III , for petitioners. Elizabeth A. Owen , for respondent. MEMORANDUM FINDINGS OF FACT AND OPI…
  15. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  16. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996related by meaning
    event the diversion of retirement savings for nonretirement purposes and to recapture a measure of the tax benefits provided by the deferral of income tax through retirement plans. At the same time, Congress recognized that it was appropriate to provide, under limited circumstances, an exemption from the tax for certai…
  17. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  18. 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…
  19. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
  20. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty. OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…