Brief Case
Pension Resource

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 98 T.C. 294 (not yet in the library — opens the official source)
94 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    have modified some parts of the 1968 regulations and would have left some parts of the 1968 regulations intact, the 1993 temporary regulations were a comprehensive set of regulations replacing the 1968 regulations in their ent irety. See T.D. 8552, 59 Fed. Reg. 34972 (July 8, 1994) (preamble to final 1994 regulations)…
  3. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …5,000 131,688 11,535 143,22 3 21 143,223 25,000 118,223 10,458 128,68 0 22 128,680 25,000 103,680 9,294 112,97 5
  4. 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
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  5. PLR 201628006 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …formation of a trust agreement for tax law purposes in Estate of La Meres v. Commissioner , 98 T.C. 294 (T.C. 1992). In La Meres , a state probate court order approved the po st-death amendment of a trust to eliminate a provision that caused adverse estate tax results, and held that such amendment was
  6. 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…
  7. 81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    nancial institution, an insurance company, or a broker-dealer. Back to Citation 8.  Cerulli Associates, “Retirement Markets 2015.” Back to Citation 9.  The Department initially proposed an amendment to its regulation defining a fiduciary within the meaning of ERISA section 3(21)(A)(ii) and Code section 4975(e)(3)(B) on…
  8. PLR 201628005 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …formation of a trust agreement for tax law purposes in Estate of La Meres v. Commissioner , 98 T.C. 294 (T.C. 199 2). In La Meres , a state probate court order approved the post-death amendment of a trust to eliminate a provision that caused adverse estate tax results, and held that such amendment was
  9. 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…
  10. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    ented are contained in pleadings and other documents in the record, and are not controverted. We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's 1991 taxable year. If respondent was not entitled to do so, then the August notice would not be valid as…
  11. PLR 200548031 — Additional Tax
    IRCPrivate Letter RulingsDec 2, 2005related by meaning
    - - - - -
  12. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…
  13. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  14. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979related by meaning
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
  15. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …d we won't therefore excuse his late filing, see, e.g., Estate of La Meres v. Commissioner, 98 T.C. 294, 317 (1992) (reliance on erroneous professional advice about filing requirement is in good faith only if the "taxpayer did not otherwise know that the return was due"). We find for the Commissioner on these additions…
  16. 34 T.C. 73 — Zeltzerman v. Commissioner
    IRCCourt RulingsApr 18, 1960related by meaning
    Section 403(a) of the Internal Revenue Code of 1954 is, in the main, a reenactment of section 22(b) (2) (B) of the Internal Revenue Code of 1939. The latter was enacted by section 162 of the Revenue Act of 1942, which also amended section 165 and section 23 (p) of the 1939 Code. The congressional committee reports deal…
  17. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …y-related penalty Year Deficiency Sec. 6662(a) 2001 $77,600 $15,520.00 2002 . 77,200 15,440.00 2003 294,777 58,955.40 Diogenes Holdings, Inc. docket No. 22515-07 Accuracy-related penalty Year Deficiency Sec. 6662(a) 2001 $61,635 $1!2,327.00 2002 61,453 , 12,290.60 2003 61,840 12,368.00 The deficiencies result froin res…
  18. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
  19. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …e portions of the opinion we choose to adopt. See Helvering v. National Grocery Co. , 304 U.S. 282, 294-295 (1938); Silverman v. Commissioner , 538 F.2d 927, 933 (2d Cir. 1976), - 69 - affg. T.C. Memo. 1974-285; IT&S of Iowa, Inc. v. Commissioner , 97 T.C. 496, 508 (1991); Parker v. Commissioner , 86 T.C. 547, 562 (198…
  20. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…