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61. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    ioners filed their memorandum on February 12, 2014, and (continued...) - 63 - As an exception to the general rule of section 1.61-22(b)(1), Income Tax Regs., an arrangement between an owner and a nonowner of a life insurance contract is a split-dollar life insurance arrangement if it is either a compensatory arrangemen…
62. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005related by meaning
    relief from joint and several liability is where the issue is properly raised in a - 11 - 5 Additionally, we have held that we may address a claim for relief from joint and several liability pleaded as an affirmative defense in a matter properly before this Court under sec. 6404 (relating to the Commissioner’s determin…
63. 76 T.C. 1048 — Arkin v. Commissioner
    IRCCourt RulingsJun 25, 1981
    …des: (f) Partner’s distributive share of contributions and deductions. (1) For purposes of sections 702(a)(8) and 704 in the case of a defined contribution plan, a partner’s distributive share of contributions on behalf of self-employed individuals under such a plan is the contribution made on his behalf, and his distr…
64. 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…
65. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
66. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    opinion, be contrary to the restrictive statutory language of section 402(e)(4)(A), and contrary to the policy considerations underlying the statute. Petitioner’s change in employment status from that of an employee to that of an independent contractor did not constitute a separation from the service within the meanin…
67. T.C. Summary Opinion 2020-14 — Dale W. Laue & Alicia Laue v. Commissioner
    IRCCourt RulingsApr 20, 2020related by meaning
    om qualified retirement plans unless one of the exceptions set forth in section 72(t)(2) applies. Section 72(t) provides in pertinent part as follows: SEC. 72(t). 10-Percent Additional Tax on Early Distributions from Qualified Retirement Plans.-- (1) Imposition of additional tax.--If any taxpayer receives any amount fr…
68. 61 T.C. 727; 61 T.C. No. 78 — Robertson v. Commissioner
    IRCCourt RulingsMar 13, 1974related by meaning
    uggestion that a Robertson representative meet with Penzner’s Kansas City officials in order that the customer correspondence file could be inspected. To the extent that 1 day’s activity could in any way be termed “consultation,” the Penzner suggestion was nothing more than a gratuitous gesture on Penzner’s part and on…
69. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981related by meaning
    with such requirements. Accordingly, the petitioners are not entitled to a deduction for Mr. Cobb’s "contribution” to an IRA made during that year. ^ The petitioners argue that if their claimed deduction for a contribution to an IRA in 1975 is disallowed, they are entitled to a loss deduction under section 165, either…
70. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    me day respondent issued to petitioner a notice and demand for payment of the unpaid interest . On or about July 25, 2000, petitioner filed Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief ), requesting section 6015 ( f) equitable relief from the unpaid interest . More tha…
71. 85 FR 81097 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage
    IRCFinal Rules (FR)Dec 15, 2020
    …ost of any tier of coverage for any class of similarly situated individuals (as described in § 2590.702(d)) by more than 5 percentage points below the contribution rate for the coverage period that includes March 23, 2010. (B) Contribution rate based on a formula. A group health plan or group health insurance coverage …
72. T.D. 9325 — Final regulations under section 401 of the Code provide rules permitting in-service distributions to be made to a participant from a pension plan upon the part…
    IRCTreasury DecisionsJun 11, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-37 Rev. Rul. 2007-37 Cancellation of distributorship agreement. This ruling holds that the cancellation of an agreement to distribute a manufacturer’s products may be a sale or exchange of property. The gain may be capital gain or treated as capital gain and may be subject to recapture. REG-14…