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 92 T.C. 776 (not yet in the library — opens the official source)
92 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    rough prosecution of a legal suit or action based upon tort or tort type rights, or - 14 - through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 65…
  2. 143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner
    IRCCourt RulingsAug 26, 2014
    …ght or a suspect category, it was constitutional if the classification had a reasonable basis. E at 776. Examining the legislative history in enacting deductions for IRA contributions, we determined that the reasonable basis was Congress' intent to make available "'a special deduction for amounts set aside for retireme…
  3. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  4. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    y at the time it was terminated and hence section 165 (b) did not apply. Eespondent has cited no case which would require a different conclusion here. On the facts here involved it is our opinion that the distribution received by petitioner in the year 1955 was paid to him on account of his separation from the service …
  5. 136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner
    IRCCourt RulingsFeb 7, 2011
    …) or the net cash-surrender value remained,greater thanszero.? Kleinman's "no-lapse" premium was $3,776.69. With the initial premium payment of only $120,000, the net cash-surrender value of her policy would have to exceed zero after only 31 months to avoid a lapse or incur an obligation to pay more premiums-. When in …
  6. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006
    … Cir. 1964). Our jurisdiction to grant equitable relief is limited. Woods v. Commissioner , 92 T.C. 776, 784-787 (1989); Estate of Rosenberg v. Commissioner , 73 T.C. 1014, 1017-1018 (1980). Accordingly, we must sustain respondent’s determination. Reviewed and adopted as the report of the Small Tax Case Division. To re…
  7. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  8. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005
    … OPINION COLVIN, Judge: Respondent determined a deficiency in petitioner's Federal income tax of $1,776 for 2001. SERVED DEC 2 9 2005 After petitioner's concession,¹ the issues for decision are whether petitioner may deduct for 2001 (1) $1,916 that she paid .. to a French retirement plan, and (2) real estate taxes. We …
  9. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996
    …nt. Estate of Lang v. Commissioner , 64 T.C. 404, 406-407 (1975), affd. on this issue 613 F.2d 770, 776 (9th Cir. 1980). However, it is equally clear that we may adopt a ruling's reasoning if it is persuasive. Neuhoff v. Commissioner , 669 F.2d
  10. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998★ strong match
    began on the date that the prohibited transaction occurred, May 31, 1988, and ended on the -14- 8 Petitioner contends that the second-tier tax of sec. 4975(b) is not applicable because of ERISA sec. 502(i), 29 U.S.C. 1132(i) (1988). ERISA sec. 502(i) provides the following: In the case of a transaction prohibited by se…
  11. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  12. T.C. Summary Opinion 2018-16 — Albert Anthony Oliver v. Commissioner
    IRCCourt RulingsApr 3, 2018
    …C. 783 (1983); see also Commissioner v. McCoy, 484 U.S. 3, 7 (1987); Woods v. Commissioner, 92 T.C. 776, 784-787 (1989); Hays Corp. v. Commissioner, 40 T.C. 436, 442-443 (1963), af[d, 331 F.2d 422 (7th Cir. 1964). We may not rewrite the law because we may deem its "effects susceptible of improvement". Commissioner v. L…
  13. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014related by meaning
    tions: (1) to an employee age 59-1/2 or older; (2) to a beneficiary (or the employee's estate) on or after the employee's death; (3) on account of the employee's disability; (4) as part of a series of substantially equal periodic payments made for life; (5) to an employee after separation from service after attainment …
  14. T.C. Summary Opinion 2017-57 — Gregory J. Gowen v. Commissioner
    IRCCourt RulingsJul 24, 2017
    …21, 2013. On his 2012 tax return petitioner reported income of $216,147 consisting of wages of $122,776, pensions and annuities of $86,000 (the total of the amounts he withdrew from his KPMG section 401(k) retirement plan account), and unemployment compensation of $7,371. Petitioner did not report the deemed distributi…
  15. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    , Pub. L. 100-647,102 Stat. 3342. No inferences as to whether or not earlier regulations are valid should be drawn from the amendment of sec. 7805(e). As noted in the facts, petitioner had 34 employees on Jan. 31, 1986, but paid bonuses to only 33 employees because one employee left the company prior to the date of pay…
  16. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ors.” Altera Corp. & Subs. v. Commissioner , 145 T.C. at 112 (quoting Sherley v. Sebelius, 689 F.3d 776, 784 (D.C. Cir. 2012) ). 208 To the extent it matters whether the Treasury Department considered the public comments, petitioner has conceded that the Treasury Department considered the public comments. First, paragr…
  17. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010
    …quently, our jurisdiction to grant equitable relief is limited . Woods v . Commissioner , 92 T .C . 776, 784-787 (1989) ; Estate of Rosenberg v . Commissioner , 73 T .C . - 8 - 1014, 1017-1018 (1980) . This Court is limited by the exceptions enumerated in section 72(t) . See, e .g ., Arnold v . Commissioner , 111 T .C …
  18. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …085 6,818 .47 1,608 .94 8,427 .4 1 1994 66 .0084 15,698 .12 1,725 .72 17,423 .8 4 1995 108 .1071 46,776 .86 6 .29 46,783 .1 5 1996 144 .5164 108,732 .69 30 .90 108,763 .5 9 1996 110,116 .148 0 1997 10,323 .9064 304,555 .24 10 .31 304,565 .5 5 'Number of shares restated to reflect a 70-to-1 stock split . After petitione…
  19. 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 …
  20. T.C. Summary Opinion 2006-177 — Richard D. Smart v. Commissioner
    IRCCourt RulingsOct 25, 2006
    …quently, our jurisdiction to grant equitable relief is limited . Woods v . Commissioner , 92 T .C . 776, 784-787 (1989) ; Estate of Rosenberg v . Commissioner , 73 T .C . 1014, 1017-1018 (1980) . This Court is limited by the exceptions enumerated in section 72(t) . See, e .g ., Arnold v . Commissioner , 111 T .C . 250,…