Search the Pension Law Library

41. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005
    …approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 1036; Rev. Proc. 2002-37, 2002-1 C.B. 1030 (certain corporations), as clarified and modified by Notice 2002-72 and modified by Rev. Proc. 2003-34; Rev. Proc. …
42. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
43. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
44. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
45. Treas. Reg. § 54.4980F-1(c7)(3) — Notice requirements for certain pension plan amendments significantly reducing the rate of future benefit accrual.
    IRCRegulationsDec 30, 2016
    …. Plan A is amended to reduce significantly the rate of future benefit accrual effective January 1, 2003. Section 204(h) notice is required to be provided 45 days before January 1, 2003. Timely section 204(h) notice is provided to all applicable individuals (and to each employee organization representing participants w…
46. T.C. Summary Opinion 2017-57 — Gregory J. Gowen v. Commissioner
    IRCCourt RulingsJul 24, 2017
    …y installments due at the end of each month. After making all monthly payments due through July 31, 2003, the participant fails to make the payment due on August 31, 2003 or any other monthly payments due thereafter. The plan administrator allows a threemonth [sic] cure period. (ii) As a result of the failure to satisf…
47. T.C. Summary Opinion 2003-13 — Mark F. Beneventi v. Commissioner
    IRCCourt RulingsFeb 20, 2003related by meaning
    …re to the Internal Revenue Code in effect for 1999, the taxable year in issue. T.C. Summary Opinion 2003-13 UNITED STATES TAX COURT MARK F. BENEVENTI, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1558-02S. Filed February 20,2003. Mark F. Beneventi, pro se. Michael K. Park , for respondent. ARM…
48. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…
49. 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 …
50. 81 FR 40548 — Deferred Compensation Plans of State and Local Governments and Tax-Exempt Entities
    IRCProposed Rules (FR)Proposed Jun 22, 2016
    …ection 457 does not apply to certain nonelective deferred compensation of nonemployees. On July 11, 2003, the Treasury Department and the IRS issued final regulations under section 457 (TD 9075) (68 FR 41230) (2003 final regulations). The 2003 final regulations provide guidance on deferred compensation plans of eligibl…
51. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    IRCCourt RulingsSep 26, 2001related by meaning
    1 All subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. T.C. Summary Opinion 2001-158 UNITED STATES TAX COURT MAJID NAEMI, Petitioner v . COMMISSIONER OF INTERNAL REVEN…
52. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
53. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
54. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
55. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    T.C. Summary Opinion 2019-26 PA UNITED STATES TAX COURT PASCAL NSAME AND LAMIAA MSALKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11462-15S. Filed September 23, 2019. Pascal Nsame and Lamiaa Msalka, pro sese. Timothy B. Heavner and Mary Ann Waters, for respondent. SUMMARY OPINION COLVIN, Ju…
56. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …19 plan) in 2001 and 2002 and to the Millennium Multiple Welfare Benefit Trust (Millennium plan) in 2003, and respondent's 1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Proc…
57. T.C. Summary Opinion 2003-161 — Martin Edward Caulfield v. Commissioner
    IRCCourt RulingsNov 7, 2003related by meaning
    …n references are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-161 UNITED STATES TAX COURT MARTIN EDWARD CAULFIELD, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19485-02S. Filed November 7, 2003. Martin Edward Caulfield, pro se. James L. May, Jr. , for…
58. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    d to an SEP plan on the basis of these earnings.6 In 2003 he contributed $12,242 to his SEP plan. In the notice of deficiency respondent determined in pertinent part that petitioner was:; (1)- A common law employee of the BCG and consequently was not entitled to report gross receipts and expenses associated with his wo…
59. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    …nial of equitable relief under the last sentence of section 66(c). Beck - 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent's denial of equitable relief under section 66(c) for abuse of discretion. Id ; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
60. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …of the Memphis and Forest Lakes properties were $92,480 and $53,880, respectively . Tax Years 2002, 2003, and 200 4 During 2002, 2003, and 2004 petitioner Daria A . Basalyk (Mrs . Basalyk) was an employee of the Brecksville-Broadview Heights Board of Education . Petitioner Peter I . Basalyk (Mr . Basalyk) was an employ…