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41. 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…
42. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …led during the Departments' two environmental scans was 5 GB. Excel's limit is 1,048,576 rows by 16,384 columns. See https://support.microsoft.com/​en-us/​office/​excel-specifications-and-limits-1672b34d-7043-467e-8e27-269d656771c3. Back to Citation 137.   See Exec. Order No. 13877, 84 FR 30849 (June 27, 2019); See als…
43. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
44. PLR 201443015 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsOct 24, 2014
    …ance companies.” Atkinson & Dallas, LIFE INSURANCE PRODUCTS AND FINANCE (Soc. Of Actuaries 2000) at 384. Describing assumption reinsurance, the United States Supreme Court stated: [T]he reinsurer steps into the shoes of the ceding company with respect to the reinsured policy, assuming all its liabilities and its respon…
45. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
46. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsOct 15, 1999
    …, and subject to the conditions and limitations specified in § 381(b) and (c), and §§ 382, 383, and 384, Company will succeed and take into account as of the close of the date of transfer (within the meaning of § 1.381(b)-1(b)(2)), the items and tax attributes of Mutual described in § 1.381(c)(22)-1, inter alia, the re…
47. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    An IRA is a qualified retirement plan to which section 72(t) (1) applies. See secs. 408(a), 4974(c) (4). Respondent introduced evidence at trial from third-party payers which established that petitioner received gross distributions of $183,007 from an IRA and that $9,166 of that amount was taxable to her. Petitioner h…
48. T.C. Memo. 2002-30 — Drew Allen Rayner v. Commissioner
    IRCCourt RulingsJan 28, 2002
    …M OPINION COLVIN, Judge : Respondent determined that petitioner has an income tax deficiency of $92,384 for 1998 and is liable for an addition to tax under section 6654 of $3,941.12 for failure to pay estimated tax. The matter is before the Court on respondent’s motion for summary judgment and motion for a penalty unde…
49. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …ow for a breach of fiduciary duty claim . See Griggs v. E.I. DuPont de Nemours & Co., 237 F.3d 371, 384 (4th Cir. 2001) (citing Varity Corp. v. Howe , 516 U.S. 489, 50 7 – 15 (1996)). And w e have recognized that an ERISA fiduciary can breach its duty to a beneficiary by failing to provide material information. See id.…
50. 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…
51. 136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner
    IRCCourt RulingsFeb 7, 2011
    …y the employee at that time. H.R. Rep. No. 70-2, sec. 165 (1927), reprinted in 1939-1 C.B. (Part 2) 384, 398-99. Congress decided in 1928 to postpone the employees' recognition of the unrealized stock appreciation until the stock was sold, so the taxable amount at distribution then became the employers' contributions p…
52. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981related by meaning
    e deductible, there must be a written instrument governing such account which was extant by the time prescribed for the making of such a contribution. During 1975, Mr. Cobb had only a Keogh account. It was not until December 15, 1976, when he executed the account registration statement with Connecticut General, that he…
53. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …ow for a breach of fiduciary duty claim . See Griggs v. E.I. DuPont de Nemours & Co., 237 F.3d 371, 384 (4th Cir. 2001) (citing Varity Corp. v. Howe , 516 U.S. 489, 50 7 – 15 (1996)). And w e have recognized that an ERISA fiduciary can breach its duty to a beneficiary by failing to provide material information. See id.…
54. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
55. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …h-care benefits is determined according to ordinary principles of contract law.” Stone , 943 F.3d at 384 (7th Cir. 2019) (citing Tackett, 574 U.S. at 435); see Barnett v. Ameren Corp. , 436 F.3d 830, 832–33 (7th Cir. 2006). Thus, to determine whether the retiree health benefit that
56. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    al right to decrease or altogether avoid such taxes by means which the law permits. Gregory v. Helvering, supra; Daniel D. Palmer, 62 T.C. 684 (1974). Respondent asserts that the result and reasoning of Rev. Rul. 68-303, 1968-1 C.B. 165, should control this case. In Rev. Rul. 68-303, a partnership entered into a contra…
57. T.C. Summary Opinion 2014-50 — Joel G. Nganga v. Commissioner
    IRCCourt RulingsJun 4, 2014
    …itioner's Federal income taxes: Penalty Year Deficiency sec. 6662(a) 2010 $17,790 $3,558.00 2011 17,384 3,476.80 After deemed concessions by petitioner and express concessions by respondent,2 the issues for decision are as follows: 1 Unless otherwise indicated, all subsequent section references are to the Internal Reve…
58. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …2,977 53,150 45 948,014 165,000 62 2,363,755 71,633 45 1,277,687 54,811 45 977,641 170,000 62 2,435,384 74,170 45 1,322,938 56,472 45 1,007,267 175,000 62 2,507,012 76,352 45 1,361,876 58,133 45 1,036,893 - 13 - In determining the permissible normal retirement benefit under the plan
59. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    payer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. - 9 - 5 See also …
60. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    IRCCourt RulingsSep 26, 2001
    …e 2 (modified AGI) exceeds $35,000 for the taxable year. 3 Petitioner reported modified AGI of $120,384.17 in 1997; thus he is not entitled to a deduction if he was an active participant in a qualified retirement plan. Petitioner does not appear to raise the issue of whether the CDI pension plan is of the type listed i…