IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…ates the updated costs as: (124,302 DB plans that use ESG × 1% of plans that have ties × 2 hours × $129.74 per hour for a plan fiduciary) + (124,302 DB plans that use ESG × 1% of plans that have ties × 2 hours × $61.01 per hour for a clerical worker) + (25,020 DC plans that use ESG × 1% of plans that have ties ×
1/3
of…
IRCCourt RulingsNov 21, 2023related by meaning
n its trade
or business, including “ rentals or other payments required to be made
as a condition to the continued use or possession ” of property.
19 Respondent also contends that petitioners failed to substantiate some of the
reported rent payments. Because we sustain respondent’s determination on other
grounds, we n…
IRCCourt RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018related by meaning
C T
T.C. Memo. 201 8-92
UNITED STATES TAX COURT
VAL LANES RECREATION CENTER CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24887-10R. Filed June 26, 2018.
James R. Monroe and Michael A. Gilmer, for petitioner.
Nicholas D. Doukas and David Conrad, for respondent.
MEMORANDUM FINDINGS O…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
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…
PBGCFinal Rules (FR)May 13, 2016
…revised to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
6. In § 4071.3, the figures “$1,100” are removed and the figures “$2,063” are added in their place.
( printed page 29767)
PART 4302—PENALTIES FOR FAILURE …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
81 FR 4599 — Applicability of Normal Retirement Age Regulations to Governmental Pension Plans IRCProposed Rules (FR)Proposed Jan 27, 2016
…as amended by section 2(a) of Defending Public Safety Employees' Retirement Act, Public Law 114-26 (129 Stat. 319) (2015)) and section 308 of Protecting Americans From Tax Hikes Act of 2015 (PATH Act), enacted as part of the Consolidated Appropriations Act, 2016, Public Law 114-113 (129 Stat. 2422), to include federal …
IRCCourt RulingsJun 3, 1998related by meaning
ication of the terms of the
underlying obligations."
Petitioners cite Tech. Adv. Mem. 93-44-001
(November 5, 1993) (the TAM) to support their position that the plan's failure to demand payment constituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a r…
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
… 28 U.S.C. 2461 note (Federal Civil Penalties Inflation Adjustment Act of 1990); and Pub. L. 114-7, 129 Stat 584.
§ 579.1
[Amended]
22. In the following table, for each paragraph indicated in the left column, remove the dollar amount indicated in the middle column from wherever it appears in the paragraph and add in it…
IRCCourt RulingsJan 5, 2017related by meaning
n has been previously rejected by this Court as baseless and subject to the
imposition of sec. 6673 penalties. See Waltner v. Commissioner, T.C. Memo. 2014-35, , __ F. App'x __, 2016 WL 5800492 (9th Cir. Oct. 5, 2016); Nelson
v. Commissioner, T.C. Memo. 2012-232, M, 540 F. App'x 924 (11th Cir.
2013).
- 10 -
[*10] suppo…
80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec… IRCFinal Rules (FR)Nov 18, 2015
ing Conditions Could Affect 1 in 2 Americans: 129 Million People Could Be Denied Affordable Coverage Without Health Reform, 2011 and Artiga, S.
et al. The Impact of the Coverage Gap in States not Expanding Medicaid by Race and Ethnicity.
The Kaiser Family Foundation,
April 2015.
Back to Citation
108.
Claxton, G. and L…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
d the earlier
of the Participant's life
expectancy * * *.
* * * * * * *
11.2 ALIENATION
(a) Subject to the exceptions provided below, and as otherwise permitted by the Code and Act, no benefit which shall be payable out
of the Trust Fund to any person (including a Participant or the
Participant's Beneficiary) shall be …
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
w why the statute as
enacted contains language different from that in the House and
- 10 -
1
We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize
this Court to grant a declaratory judgment include secs. 6234,
7428, 7477, 7478, and 7479.
2
Sec. 7503 a…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
83 FR 1555 — Adjustment of Civil Penalties for Inflation PBGCFinal Rules (FR)Jan 12, 2018
…ntinues to read as follows:
Authority:
28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371.
§ 4071.3
[Amended]
2. In § 4071.3, the figures “$2,097” are removed and the figures “$2,140” are added in their place.
PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MUL…
T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…