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82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013
    … be resolved on the basis of all the facts and circumstances. Thomas v. Commissioner, 31 T.C. 1009, 1012 (1959); S. Ford Tractor Corp. v. Commissioner, 29 T.C. 833, 842 (1958). Petitioner contends that the rent amounts paid to Lipspaces, a related party, for each year in issue were reasonable and, therefore, deductible…
  2. 125 T.C. No. 11 — Estate of Doris F. Kahn, Deceased; LaSalle Bank, N.A., Trustee & Executor v. Commissioner
    IRCCourt RulingsNov 17, 2005
    …arketable securities and would obtain a tax basis in the assets equal to the buyer's cost. See sec. 1012. The buyer would only have taxable gain on the disposition of the marketable securities to the extent they appreciated in value subsequent to the time of acquisition. There'fore, the buyer would be willing to pay th…
  3. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  4. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ed work in her capacity as Yolo's employee or officer. Consistent with our conclusion above, we sustain respondent's disallowance of these deductiòns. IV. Additions to Tax and Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the …
  5. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
  6. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989
    …oner’s argument implicates facts beyond those stipulated (cf. Hughes v. Commissioner, 42 T.C. 1005, 1012 (1964)), and respondent would be unfairly prejudiced by permitting the argument. Application of Section 1.415-6(b)(6), Income Tax Regs. Petitioners’ next argument is that respondent abused his discretion in not perm…
  7. 72 T.C. 1088; 1 Employee Benefits Cas. (BNA) 1830 — Caterpillar Tractor Co. v. Commissioner
    IRCCourt RulingsSep 13, 1979
    …, which found their way into section 411(a) in its final form. See H.R. 2, 93d Cong., 2d Sess. sec. 1012, as passed by the House of Representatives on February 28,1974, and section 221, as passed by the Senate on March 4, 1974. The second element is that the Conference Committee, which was charged with compromising the…
  8. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980
    …99 (1964), affd. 352 F.2d 306 (9th Cir. 1965). In Pulver Roofing Co. v. Commissioner, 70 T.C. 1001, 1012 (1978), appeal dismissed (2d Cir. 1979), we said: “Our concern in Lansons was that minor year-to-year fluctuations in coverage due to extraneous factors would result in a plan being qualified in one year and nonqual…
  9. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
  10. Treas. Reg. § 54.6011-1(b) — General requirement of return, statement, or list.
    IRCRegulationsDec 30, 2016related by meaning
    (b) (b) Tax on prohibited transactions. Every disqualified person (as defined in section 4975(e)(2)) liable for the tax imposed under section 4975(a) with respect to a prohibited transaction shall file an annual return on Form 5330 and shall include therein the information required by such form and the instructions iss…
  11. ERISARegulationsJul 27, 2020related by meaning
    (e) (e) Limitations. This section does not apply to disclosures required under provisions of part 2 and part 3 of the Act over which the Secretary of the Treasury has interpretative and regulatory authority pursuant to Reorganization Plan No. 4 of 1978.
  12. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
    IRCFinal Rules (FR)Sep 19, 2013
    …sis of eligible building property owned by the taxpayer means the basis as determined under section 1012, or other applicable sections of Chapter 1, including subchapters O (relating to gain or loss on dispositions of property), C (relating to corporate distributions and adjustments), K (relating to partners and partne…
  13. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  14. 100 T.C. 216; 100 T.C. No. 15 — Halliburton Co. v. Commissioner
    IRCCourt RulingsMar 24, 1993
    …upon “termination” of a plan. Employee Retirement Income Security Act of 1974, Pub. L. 93-406, sec. 1012(a), 88 Stat. 912; H. Conf. Rept. 93-1280, at 277 (1974), 1974-3 C.B. 415, 438; S. Rept. 93-383, at 50 (1973), 1974-3 C.B. (Supp.) 80, 129; sec. 1.401-6(b)(2), Income Tax Regs., T.D. 6675, 1963-2 C.B. 151; see also A…
  15. ERISA § 113(f) (29 U.S.C. § 1032) — Notice and disclosure requirements with respect to lump sums
    ERISACode / StatuteJan 6, 2025related by meaning
    (f) (f) Biennial report Not later than the last day of the second calendar year after the calendar year including the applicability date of the final rules under section 342(e) of the SECURE 2.0 Act of 2022, and every 2 years thereafter, so long as the Secretary has received notices and post-offer reports under subsect…
  16. 75 FR 32846 — Final Rule Relating to Time and Order of Issuance of Domestic Relations Orders
    ERISAFinal Rules (FR)Jun 10, 2010
    …n for part 2530 is revised to read as follows: Authority: Secs. 201, 202, 203, 204, 210, 505, 1011, 1012, 1014, and 1015, Pub. L. 93-406, 88 Stat. 852-862, 866-867, 894, 898-913, 924-929 (29 U.S.C. 1051-4, 1060, 1135, 26 U.S.C. 410, 411, 413, 414); Secretary of Labor's Order No. 13-76. Section 2530.206 also issued unde…
  17. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  18. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
  19. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    PBGCRegulationsJan 1, 2017
    …t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
  20. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004related by meaning
    find Congress intended the Secretary to prescribe the regulation as to the form of the election. First, the regulation was prescribed by the Secretary pursuant to the specific grant of authority stated in section 1042(a) that authorizes him to prescribe the form in which “the application of this section with respect to…