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61. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
62. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …(3) the business purpose of the expenditure or use. Sanford , 50 T.C. at 827; Temp. Treas. Reg. § 1.274-5T(a). Substantiation for this purpose requires the taxpayer to maintain an account book, a diary, a log, a statement of expenses, trip sheets, or a similar record prepared contemporaneously with the expenditure and …
63. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …(Year 1 Only) $1,580,009 $0 $4,224,622 $4,224,622 Subtotal: Costs (Year 1 Only) $86,907,365 $79,988,274 $79,988,274 $99,365,627 Printing and Postage Cost Additional Pension Benefit Statements (Year 1) $47,024,610 $74,835,538 $0 $37,417,769 Printing and Postage Cost Additional Pension Benefit Statements (Year 2) 1 $40,7…
64. T.C. Memo. 2008-17 — Herbert & Christine Bangs v. Commissioner
    IRCCourt RulingsJan 31, 2008related by meaning
    er sec . 6662(a) . A - 23 - To reflect the foregoing, Decision will be entered for p etitioners in l ocket No . 4467-06 . Decision w 11 be entered for respondent as t the deficiency and for petitioners as to the accuracyrelated penalty under sectio n 6662(a) in docket No . 7221-06 .
65. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    e rules regarding other penalties listed in section 6662(b). See § 6662(c), (e)(1), (f)(1), (g)(1), (j)(1), (k) (each beginning with the phrase “[f]or purposes of this section” and explaining the meaning of terms such as “negligence,” “substantial valuation misstatement,” and so on). 11 Section 6664(c) is titled “ Reas…
66. T.C. Memo. 2008-249 — David A. Hughes v. Commissioner
    IRCCourt RulingsNov 3, 2008
    …affg, . T . C :-,Memo . 1984-533 . As mentioned,, certain business expenses -described' in= section 274 .(d) are subject to strict . substantiation .rules .that supersedethe Cohan rule . Sanford v . Commissioner , . 50 T- .C . 823,E 827-828 (1968), affd . 412 F .2d 201 .(2d -Cir . 1969) . ; sec . :1 .274-'5T(a) ,` Temp…
67. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
68. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    ng to the taxpayer's trade or business". Sec. 1.162-1(a), Income Tax Regs. Section 274 requires stricter substantiation for travel, meals, and certain listed property such as passenger automobiles. See Sanford v. Commissioner, 50 T.C. 823, 828 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); sec. 1.2745T(a), Temp…
69. 85 FR 6046 — Miscellaneous Corrections, Clarifications, and Improvements
    PBGCFinal Rules (FR)Feb 4, 2020related by meaning
    te for any affected party, file with PBGC a post-distribution certification (PBGC Form 501), completed in accordance with the instructions thereto; or (2)(i) Within 30 days after the last distribution date for any affected party, certify to PBGC, in the manner prescribed in the instructions to PBGC Form 501, that the p…
70. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …e away from home) may not be estimated because of the strict substantiation requirements of section 274(d).. See secs. 274(d), 280F(d)(4); Sanford v. Commissioner, 50 T.C. 823, 827-828 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969). To substantiate a deduction for those expenses, a taxpayer must maintain adequat…
71. T.C. Memo. 2000-250 — Susan Jane Hoyez, C.P.A. v. Commissioner
    IRCCourt RulingsAug 10, 2000related by meaning
    6, 682 (1977); Pawlak v. Commissioner , T.C. Memo. 1995-7. Finally, there is no indication - 8 - 2 Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be retroactively applied to the previous year if the contributions are made by the due date of the employer’s r…