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89 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    … , supra at 323-324; Horner v. Acosta , 803 F.2d 687, 693 (Fed. Cir. 1986); Spirides v. Reinhardt , 613 F.2d 826, 832 (D.C. Cir. 1979); Weber v. Commissioner , 103 T.C. at 387; Profl. & Executive Leasing, Inc. v. Commissioner , supra at 232; Simpson v. Commissioner , supra at 984-985; see also sec. 31.3401(c)-1(b), Emp…
  2. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
  3. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    …rtain situations include “deemed § 125 compensation”. 416: Section 416 of the Code was amended by § 613 of EGTRRA (as amended by § 411(k) of JCWAA) to make several changes to the top-heavy rules. Section 416(g)(4)(H) of the Code was added by § 613(d) of EGTRRA to provide certain safe harbor § 401(k) plans and § 401(m) …
  4. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
  5. Notice 2004-84 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Announcement 2004-71, 2004-40 I.R.B. 569, pertaining …
    IRCNoticesModified Dec 27, 2004
    ed soon. 416: Section 416 of the Code was amended by § 613 of EGTRRA (as amended by § 411(k) of JCWAA) to make several changes to the top-heavy rules. Section 416(g)(4)(H) of the Code was added by § 613(d) of EGTRRA to provide certain safe harbor § 401(k) plans and § 401(m) plans an exemption from the top-heavy rules. …
  6. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … than $8.8 trillion in assets.[114] The Department assumes that 85 percent of these plans, or about 613,000 plans, rely on service providers to guide the plan fiduciary.[115] ( printed page 16112) 12.6.2. Plans That Would Hold New Alternative Investments
  7. 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 …
  8. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  9. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    … $148,625 Policy values 177,103 177,103 186,612 178,964 177,545 Surrender value 157,104 157,104 166,613 161,097 162,772 Addit. contr. available 202,263 197,155 248,761 243,663 296,318 Date of report 09/94 03/95 09/94 03/95;10/95 10/95 On March 31, 1989, Prime forwarded to On-Site its 1988 summary plan description. On A…
  10. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …missioner , 674 F.2d 570, 573 (6th Cir. 1982), affg. T.C. Memo. 1978-434; Gardner v. Commissioner , 613 F.2d 160 (6th Cir. 1980), affg. T.C. Memo. 1976-349; Wortham Mach. Co. v. United States , 521 F.2d 160, 164 (10th Cir. 1975); Noble v. Commissioner , 368 F.2d at 442; Sachs v. Commissioner , 277 F.2d 879, 882 (8th Ci…
  11. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    d in section 401(a). See sec. 4974(c). Section 72(t)(2) provides - 6 - [*6] exceptions to imposition of the additional tax, including an exception for distributions made to taxpayers 59-1/2 years old or older. The term "deficiency" is, in general, defined as the excess (if any) of the tax imposed over the amount shown …
  12. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008
    …ices of deficiency relating to 2002 and 2003 determining income tax deficiencies of $15,758 and $14,613, respectively . Respondent - 3 - also determined that petitioner was li ble for a section 6651(a)(1) addition to tax for failure to timely file tax returns relating to 2002 and 2003, a section 6 51(a)(2) addition to …
  13. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996
    …26 (1985), 19863 C.B. (Vol.2) 1, 727-729; S. Rept. 99-313 (1985), 1986-3 C.B. - 7 - (Vol. 3) 1, 612-613. Petitioner failed to prove to the Court that the omission in the statute of an exemption from the additional tax under section 72(t) for financial hardships, as opposed to those resulting from death or disability, w…
  14. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    107 T.C. No. 16 UNITED STATES TAX COURT SCHMIDT BAKING COMPANY, INC., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10458-95. Filed November 14, 1996. P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. T…
  15. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  16. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012related by meaning
    ditional tax provided by section 72(t)), penalties, and statutory interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record . 12 - does not establish that petitioners received a.notice of deficiency for 2007 and consequently a challenge to petitioners' 2007 tax liability is allowed in thi judicial p…
  17. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018
    … the requirements of section 162 is a question of fact. Cloud v. - 10 - [*10] Commissioner, 97 T.C. 613, 618 (1991) (citing Commissioner v. Heininger, 320 U.S. 467, 473-475 (1943)). A. Schedule C Trade or Business Expenses Whether a taxpayer is engaged in a trade or business is a question of fact to be decided on the b…
  18. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    Eanes as petitioner. In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
  19. 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…
  20. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    … not "exercise professional judgment that is beyond the expert's ken". Dura Auto. Sys., 285 F.3d at 613. If she had, there might have been a question as to whether Ms. Ho was functioning as a mere "mouthpiece of a scientist in a different specialty". R at 614. But as it stands, nothing suggests that Ms. Ho's assistant …