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87 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996
    …ee Commissioner v. McCoy , 484 U.S. 3, 7 (1987); 508 Clinton Street Corp. v. Commissioner , 89 T.C. 352, 354 (1987). Decision will be entered for respondent with respect to the deficiency, including the additional tax under sec. 72(t), and decision will be entered for petitioners with respect to the penalty under sec. …
  2. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    ave specified, petitioner’s arrangements were vague and did not provide the employees with nonforfeitable rights to particular portions of the moneys. In reliance on the above, it follows that section 404(b) is inapplicable to petitioner, and accordingly, petitioner cannot deduct the $16,123 “contribution” pursuant to …
  3. T.C. Summary Opinion 2017-72 — Kevin C. Harris & Teresa A. Harris v. Commissioner
    IRCCourt RulingsSep 7, 2017
    …eview a refusal by the IRS to abate interest. See 508 Clinton Street Corp. v. Commissioner, 89 T.C. 352, 356 (1987). In 1996 Congress supplied the Tax Court with jurisdiction through what is now designated section 6404(h) to determine whether the IRS's failure to abate interest under section 6404 constituted an abuse o…
  4. 81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    under section 4975 of the Code] is hereby transferred to the Secretary of Labor”). Back to Citation 9.  29 CFR 2550.408b-2(e); 26 CFR 54.4975-6(a)(5). Back to Citation 10.   See PTE 86-128, Exemption for Securities Transactions Involving Employee Benefit Plans and Broker-Dealers, 51 FR 41686 (November 18, 1986), as ame…
  5. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  6. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …Amendments, ch. 842, sec. 11, 54 Stat. at 1096 (1940) (codified as amended at - 46 - 45 U.S.C. sec. 352(d) (2012 & Supp. I 2013)) (all using the phrase "against equity or good conscience"); see also 5 U.S.C. secs. 5584(a), 8346(b), 8470(b) (2012); 10 U.S.C. secs. 1442, 1453(b)(2) (2012); 37 U.S.C. secs. 303a(e), 373(b)…
  7. 54 T.C. 953 — Estate of Benjamin v. Commissioner
    IRCCourt RulingsMay 11, 1970related by meaning
    xtent such amounts are attributable to contributions made on behalf of the employee while he was an employee within the meaning of section 401(c) (1). [The statutory references are to the Internal Revenue Code as it presently reads. Changes which were enacted subsequent to the taxable years in question do not affect th…
  8. T.C. Memo. 2008-17 — Herbert & Christine Bangs v. Commissioner
    IRCCourt RulingsJan 31, 2008
    …61(a)(11) and on cases (e .g ., Pfister v . Commissioner , T .C . Memo . 2002-198, affd . 359 F .3d 352 (4th Cir . 2004), and Witcher v . Commissioner, T .C . Memo . 2002-292) in which the Court based its respective holdings on that section . Although sec . 61(a)(11) provides the general rule that gross income includes…
  9. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    as provided in paragraphs (3) and (4), paragraph (1) shall not apply to any of the following distributions: (A) In general.--Distributions which are-- (i) made on or after the date on which the employee attains age 59 1/2, (ii) made to a beneficiary (or to the estate of the employee) on or after the death (continued...…
  10. T.C. Memo. 1998-30 — Brian J. Patrick v. Commissioner
    IRCCourt RulingsJan 26, 1998
    …through 1994, Wayne received wages, interest and dividend income totaling $13,439, $45,359, and $57,352, respectively. Petitioners' inability, ab initio, to meet their contractual obligation to service these "loans" is evidence that petitioners had no intention of treating the transactions as bona fide debt. We also no…
  11. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  12. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    …d and contends that such amount is deductible as compensation to petitioner; respondent conceded 18,352. 9,961 legal and The corporation conceded professional fees 6,161.35 to be an amount that was wire transferred to petitioner and 3,800 to be petitioner's personal business and investment expense. The corporation cont…
  13. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
  14. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
  15. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    4(a)(1) exclude541 from Mr. Fernandez' income the amounts he received from - 6 - LACERA. The question is whether the same section excludes the amounts petitioner received attributable to Mr. Fernandez' benefits under the stipulated division of retirement benefits. . Petitioner argues that the $11,691 is excluded from h…
  16. 81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    of the Code and a health savings account described in section 223(d) of the Code. Back to Citation 19.  Code section 4975(c)(2). Back to Citation 20.  Angela A. Hung, Noreen Clancy, Jeff Dominitz, Eric Talley, Claude Berrebi, Farrukh Suvankulov, Investor and Industry Perspectives on Investment Advisers and Broker-Deal…
  17. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  18. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …f certain sale proceeds) , aff’d , 240 F.3d 369 (4th Cir. 2001) ; O’Malley v. Commissioner, 91 T.C. 352, 361 (1988) ( holding that taxpayer realized gross income where a pension fund paid his legal fees related to a criminal indictment ) ; Huff v. Commissioner , 80 T.C. 804, 814 (1983) ( holding that payment by a third…
  19. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995
    …out published opinion 921 F.2d 280 (9th Cir. 1991); 508 Clinton St. Corp. v. Commissioner , 89 T.C. 352 (1987). Although there are certain narrowly defined exceptions to this rule, none of them apply in this case. See, e.g., sec. 7481(c); Bax v. Commissioner , 13 F.3d 54 (2d Cir. 1993). In short, it is simply not withi…
  20. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …