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 T.C. Memo. 2013-225 (not yet in the library — opens the official source)
70 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  2. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  3. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    T.C. Summary Opinion 2013-51 UNITED STATES TAX COURT MARTIN TOOMBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27665-10S. Filed June 25, 2013. James O. Creech III, for petitioner. Thomas D. Yang, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the p…
  4. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    …ess petitioner qualifies for an exception. See sec. 72(t) (1); see also Stipe v. Commissioner, T.C. Memo. 2011-92; Dollander v. Commissioner, T.C. Memo. 2009-187. Petitioner has not alleged that any exception applies, nor has he introduced any evidence that could allow us to conclude that an exception applies. Therefor…
  5. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010related by meaning
    … a matter which is within the discretion of the Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd . 122 Fed . Appx . 788 (5th Cir . 2005) . Furthermore,petitioners have failed to identify a ministerial or managerial delay by an IRS employee that cause d ,them to forgo making payments on their . i…
  6. 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…
  7. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    65 cz T.C. Memo. 2017-5 UNITED STATES TAX COURT BRIAN E. HARRISS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 12528-14, 25358-14. Filed January 5, 2017. Brian E. Harriss, pro se. Randall B. Childs and Caroline R. Krivacka, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge…
  8. T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner
    IRCCourt RulingsJan 19, 2016related by meaning
    MN T.C. Memo. 2016-10 UNITED STATES TAX COURT FAMILY CHIROPRACTIC SPORTS INJURY & REHAB CLINIC, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 29613-13R. Filed January 19, 2016. Richard W. Leavitt (an officer) and Mark Eldridge (trustee), for petitioner. Shawn P. Nowlan, for respondent. MEM…
  9. 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 …
  10. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019
    professional basketball player who, in 2013, was convicted in Federal court of wire fraud for running a real estate Ponzi scheme. See United States v. George, 684 F. App'x 223 (3d Cir. 2017). Petitioner was incarcerated for the whole of 2013, and he has remained incarcerated to the present. He is scheduled for release …
  11. 88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates
    PBGCFinal Rules (FR)Nov 7, 2023related by meaning
    …006(a)(3)(F) of ERISA reads, “For each plan year beginning in a calendar year after 2006 and before 2013. . .” and section 4006(a)(3)(H) of ERISA refers to 4006(a)(3)(A)(iv), which says, “in the case of a multiemployer plan, for plan years beginning after December 31, 2005, and before January 1, 2013.” Back to Citation…
  12. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    es of $53,114 from AT&T in 2013 and $5,984 from Ad Susman & Associates, Inc., in 2014. After losing his job with AT&T Mr. Pokawa withdrew money from a retirement account to invest in various business activities. The withdrawals were reported on Forms 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-…
  13. PLR 201720009 — Definitions and Special Rules
    IRCPrivate Letter RulingsMay 19, 2017related by meaning
    Internal Revenue Service Department of the Treasury Wa shington, DC 20224 Number: 201720009 Release Date: 5/19/2017 Index Number: 414.00-00, 414.09-00 -------------------------- ------------------------------------------------------------ - --------------------------------------------------------- ---------------------…
  14. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …upon an opinion rendered by this Court on June 8, 2009, in HIE Holdings, Inc. v. Commissioner, T.C. Memo. 2009-130 (deficiency case), affirmed by the Court of Appeals for the Ninth Circuit on April 5, 2013, 521 Fed. 'All section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all…
  15. T.C. Memo. 2006-95 — Theodus J. Jordan v. Commissioner
    IRCCourt RulingsMay 8, 2006related by meaning
    002, it could not have been determined whether petitioner had any overpayment with respect to taxable year 2002. petitioner’s overpayment for 2001. 10 The disallowance of the credit that petitioner claimed with respect to this item does not affect the amount of petitioner’s deficiency for 2002. See sec. 6211(a) (defini…
  16. 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…
  17. 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…
  18. TR 2013-03 — Technical Release 2013-03
    ERISADOL Technical ReleasesSep 13, 2013
    …ge, unused amounts credited before January 1, 2014 consisting of amounts credited before January 1, 2013, and amounts that are credited in 2013 under the terms of an HRA as in effect on January 1, 2013, may be used after December 31, 2013 to reimburse medical expenses in accordance with those terms without causing the …
  19. T.C. Memo. 2018-49 — Stacey S. Marks v. Commissioner
    IRCCourt RulingsApr 10, 2018related by meaning
    JRN T.C. Memo. 2018-49 UNITED STATES TAX COURT STACEY S. MARKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18520-16. Filed April 10, 2018. Ray C. Mayo, Jr., for petitioner. Donielle A. Hubbard, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: Respondent mailed petition…
  20. 78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal
    IRCProposed Rules (FR)Proposed Aug 8, 2013
    tten Appraisal to the consumer. 12 CFR 1026.35(c)(6). The requirements provided in the 2013 Final Rule were described in the PRA section of that rule. See78 FR 10368, 10429 (February 13, 2013). As described in its section 1022 analysis in the 2013 Final Rule and in Table 3 to that rule, the estimated burdens allocated …