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41. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …t of Labor, Transcript of Press Conference on Corporate Activist Role in Pension Planning (July 28, 1994), at 15-16 (then-Secretary Robert Reich stating that IB 94-2 “makes very clear that . . . pension fund managers, trustees, [and] fiduciaries have an obligation to vote proxies” unless the costs “substantially outwei…
42. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6723-93. Filed December 23, 1996. Alfred P. Duffy, pro se. Judith Wilkie , for respondent. ME…
43. 84 FR 53579 — Real Estate Appraisals
    IRCFinal Rules (FR)Oct 8, 2019
    etermine changes in house prices since 1994. The agencies also analyzed general measures of inflation by reviewing the Consumer Price Index (CPI).[35] A residential property that sold for $250,000 as of June 30, 1994, would be expected to sell in March 2019 for $643,750 according to the Case-Shiller Index and $621,448 …
44. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    JMP T.C. Memo. 2011-56 UNITED STATES TAX COURT DELORES CHENAULT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent I Docket No. 22806209L. Filed March^9, 2011. Delores Chenault, pro se. John S. Hi~t-t ind Mayer Y. Silber, for' respondent. MEMORANDUM OPINION LARO, Judge: Petitioner petitioned the Court under se…
45. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
46. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998
    …he year in issue petitioner worked for Key Trucking, Inc. (Key), as a salesman. At the beginning of 1994 petitioner was paid a salary by Key. In late January or early February, Key ceased paying petitioner a salary, and, instead, - 3 - paid him commissions on his sales. In August 1994, Key resumed paying petitioner a s…
47. T.C. Memo. 1996-545 — Creston Swaim v. Commissioner
    IRCCourt RulingsDec 17, 1996related by meaning
    …e Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. T.C. Memo. 1996-545 UNITED STATES TAX COURT CRESTON SWAIM, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20684-94. Filed December 17, 1996. Creston Swaim, pro se. Michael D. Zima , for respondent. MEM…
48. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    ant to that addendum, on January 12, 1994, Burien Nissan canceled Mr. Buchner’s 5,880 shares of stock as well as the 61,200 remaining Johnston shares. As a result of the addendum to the May 25, 1990 stock purchase agreement, as of January 12, 1994, the ownership of Burien Nissan stock was as follows: Stockholder Number…
49. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    …ent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissioner , T.C. Memo. 1998-203 (reaching this conclusion regarding another question and answer contained in the same proposed regulation), affd. without published opinion 190 F.3d 538 (5th Cir. 1999). Additionally, the substantially lev…
50. T.C. Memo. 1998-379 — Dale Reid Edmonds v. Commissioner
    IRCCourt RulingsOct 20, 1998
    …spondent contends that petitioner did not make a qualified retirement contribution to an IRA during 1994. In the - 6 - alternative, respondent argues that, even if petitioner did make a qualified IRA contribution during 1994, he is precluded by the limitations of section 219(g) from deducting such contribution. Petitio…
51. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016related by meaning
    ple, Deputy Commissioner for Services and Enforcement. Approved: April 29, 2016. Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy). Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011) [1] Section 20…
52. T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr…
    IRCTreasury DecisionsDec 9, 2013related by meaning
    of safe harbor matching contributions for plan years beginning on or after January 1, 2015. EMPLOYMENT TAX T.D. 9646 T.D. 9646 REG–146620–13T.D. 9646 Temporary and proposed regulations under section 3402(p)(3) relating to voluntary withholding agreements allow the Secretary to issue guidance in the Internal Revenue Bu…
53. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
54. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    he penalties in docket Nos. 2545-94 and 9230-94; an appropriate decision for respondent will be entered in docket No. 5754-94 as to the deficiency and the addition to tax under section 6651(a)(1) and for petitioner with respect to the penalty .
55. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000
    …s liable for accuracy-related penalties under section 6662(a) for the underpayment of taxes for the 1994 and 1995 taxable years; and (6) whether a penalty should be awarded to the United States under section 6673. For clarity and simplicity, we have combined the findings of fact and conclusions of law. Some of the fact…
56. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
57. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    …vid E. and Gladys A. Christie, docket No. 20363-94; and Dura-Craft, Inc., docket No. 20560-94. T.C. Memo. 1997-147 UNITED STATES TAX COURT MILO G. AND SARAH E. CHAPMAN, ET AL., 1 Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 20342-94, 20363-94, Filed March 20, 1997. 20560-94. Joann K. Beck , …
58. Treas. Reg. § 1.401(a)(4)-13(c)(6) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …lied by the employee's years of service for Employer X up to 40. (b) For plan years beginning after 1994, Employer X amends the plan formula to provide a normal retirement benefit of 0.75 percent of average annual compensation up to covered compensation multiplied by the employee's total years of service for Employer X…
59. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    e home. In 1994, petitioner paid a $10,000 consulting fee relating to a family business plan and to the acquisition and the sale of personal property. In 1994, petitioner received $5,149 as a distribution from an individual retirement account (IRA) that petitioner maintained at Great-West Life & Annuity Insurance Co. (…
60. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    ng a deficiency after issuing a refund. McCree v. Commissioner, at *18-*20. It is clear from our review of the record that SO Taylor verified that the requirements of any applicable law and administrative procedure were followed - 20 - [*20] and that in sustaining the proposed levy against petitioner, SO Taylor properl…