IRCCourt RulingsFeb 12, 2003related by meaning
(hereinafter the CONTROLLING CASE).
3. All issues involving the above adjustments shall be
resolved as if the petitioner in this case were the same as the taxpayer in the CONTROLLING CASE.
Both stipulations to be bound also provided:
4. A decision shall be submitted in this case when the
decision in the CONTROLLING CAS…
84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…l entity.
Back to Citation
146.
See 5 U.S.C. 603, 604, and 605. Back to Citation
147.
See 13 CFR 121.201.
Back to Citation
148.
12 CFR part 217.
Back to Citation
149.
12 CFR part 249.
Back to Citation
150.
5 U.S.C. 601
et seq.
Back to Citation
151.
The SBA defines a small banking organization as having $550 mill…
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…ternative Investments
(2013) (available at www.oig.dol.gov/public/reports/oa/2013/09-13-001-12-121.pdf);
U.S. Gov't Accountability Office, GAO-12-665, Private Sector Pensions: Federal Agencies Should Collect Data and Coordinate Oversight of Multiple-employer Plans
(2012) (available at
www.gao.gov/assets/650/648…
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
76 FR 67105 — Cash Balance Plans; Benefit Determinations and Plan Valuations for Statutory Hybrid Plans; Pension Protection Act of 2006 PBGCProposed Rules (FR)Proposed Oct 31, 2011
… part.
(3)
Involuntary termination exception.
If a benefit payment is calculated pursuant to § 4022.121(a)(3)(ii), the benefit will be valued based on the interest crediting rate and the annuity conversion rate in effect under the plan as of the plan's termination date (subject to the rules of §§ 4022.121 through 4022.…
IRCCourt RulingsAug 10, 2015related by meaning
mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo.
2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144.
- 12 -
II. Section 1839
A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and
necessary expenses incurred in conducting a trade or business or for the
production of income. Se…
IRCCourt RulingsApr 22, 2003related by meaning
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
IRCCourt RulingsSep 25, 2019related by meaning
…s but
instead must set forth specific facts showing that there is a genuine dispute for
trial. Rule 121(d); see Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
- 11 -
[*11] (1992), affd, 17 F.3d 965 (7th Cir. 1994); Murphy v. Commissioner, T.C.
Memo. 2019-72, at *7.
The regulations provide that a taxpayer has reason…
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…
ERISADOL Technical ReleasesNov 6, 2014
… Act" refers to the Patient Protection and Affordable Care Act (enacted March 23, 2010, Pub. L. No. 111-148), as amended by the Health Care and Education Reconciliation Act of 2010 (enacted March 30, 2010, Pub. L. No. 111-152), and as further amended by the Department of Defense and Full-Year Continuing Appropriations …
IRCCourt RulingsNov 28, 2001related by meaning
sfies the criteria, inter
alia, of having gross income that is less than $10,000 and that
includes no income other than wages, dividends, or interest. Sec. 6014(b) directs the Commissioner to prescribe regulations to
extend this authority to cases where the taxpayer has gross
income of $10,000 or more. Pursuant to this…
Notice 2008-94 — This notice provides guidance on certain executive compensation provisions of the Emergency Economic Stabilization Act of 2008 (EESA). Section 302 of EESA adde… IRCNoticesNov 3, 2008
…hases) exceeds $300 million in the aggregate, the financial institution is prohibited under section 111(c) during the TARP authorities period from entering into any new employment contract with a senior executive officer that provides a golden parachute in the event of involuntary termination from employment, bankruptc…
IRCCourt RulingsSep 14, 1993related by meaning
nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if—
(i) such lump sum distribution is received by an ind…
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
- 6 -
Respondent does not dispute that petit…
IRCCourt RulingsNov 28, 2023
… specific facts, by affidavit or otherwise, showing that there is a genuine dispute for trial. Rule 121(d);
see Sundstrand Corp. , 98 T.C. at 520.
Because petitioner did not respond to the Motion for Summary
Judgment, we could enter a decision against h er for that reason alone.
See Rule 121(d). We will nevertheless co…
IRCCourt RulingsOct 8, 2003related by meaning
f proof in this case
is affected by the fact that we carefully scrutinize transactions
between related parties, Maxwell v. Commissioner
, 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner
, 49 T.C.
649, 656 (1968), remanded pursuant to stipulation of the parties
406 F.2d 290 (6th Cir. 1969), and that…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsOct 1, 2025
is entitled
to judgment as a matter of law . See Rule 121(a)(2); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant summary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party. Sundstrand Corp. , 98 T.C.
at 520. The nonmoving party may …
IRCCourt RulingsFeb 22, 2010related by meaning
inal reserve value was purportedly only
$305,866 .74 in the light of their representation that Hartford
Life maintained a reserve of $1,035,030 .
23 - patently improper ." Sec . 1 .6662-3(b)(3), Income Tax Regs . This
standard is satisfied if the return position is reasonably . based
on various types of enumerated auth…
ERISACourt RulingsFeb 22, 2000
… the documents, with specific reference to individual
participants, including Ms. Palaoro, (T 117 - 121) and continued on
with other individual accounts. (T 121 - 126).
The documents were finally finished, and he
mailed the individual participant account statements for all of the
Plan years due, on April 1, 1999. (T 12…