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89 documents · 0.19sAllIRCERISAPBGCJoint 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. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
  3. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
    IRCCourt RulingsJul 3, 1974related by meaning
    conclusion since it was based solely on estimates of anticipated revenue loss and not on a disclaimer by Congress of the principles contained therein. We have discovered no prior case law authority that resolves the precise issue before us. We believe, however, that our conclusion finds support in New York Post Corp., …
  4. 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…
  5. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980related by meaning
    er Sheet Metal, Inc. v. Commissioner, 53 T.C 385 (1969); Liberty Machine Works, Inc. v. Commissioner, 62 T.C. 621 (1974), affd. 518 F.2d 554 (8th Cir. 1975); Peter F. Mitchell Corp. v. Commissioner, T.C. Memo. 1968-209, supplemental opinion, T.C. Memo. 1969-73. The District Court in Container Service Co. v. United Stat…
  6. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
  7. 67 T.C. 411; 1 Employee Benefits Cas. (BNA) 2232 — Hill, Farrer & Burrill v. Commissioner
    IRCCourt RulingsDec 14, 1976related by meaning
    . 401(d)(3)(A) and (B). Sec. 401(d)(2)(A). Sec. 401(d)(2)(B). Sec. 401(d)(5); sec. 404(e)(1), (e)(2)(A), and (e)(4). Sec. 72(m)(5). Sec. 401(a)(9)(A). Sec. 406, Employee Retirement Income Security Act of 1974; sec. 4975; see also former sec. 503(j), which accompanied the adoption of sec. 401(c)(3)(B). H. Rept. No. 378,…
  8. 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)…
  9. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  10. 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…
  11. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977related by meaning
    t rule is to protect the fund from unauthorized transactions, whether or not those transactions actually result in a loss of benefits to the employee. By our holding here, we do not mean to imply that the exclusive benefit rule is contravened whenever a benefit inures to someone other than the employees or their benefi…
  12. 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…
  13. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    or assets of a plan; (5) act by a disqualified person who is a - 15 - [*15] fiduciary whereby he deals with the income or assets of a plan in his own interests or for his own account; or (6) receipt of any consideration for his own personal account by any disqualified person who is a fiduciary from any party dealing w…
  14. 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…
  15. IRCCourt RulingsOct 4, 1979related by meaning
    be based on principles similar to the principles which apply in the case of subsection (b). [Emphasis added.] SEC. 414. DEFINITIONS AND SPECIAL RULES. (b) Employees of Controlled Group of Corporations. — For purposes of sections 401,408(k), 410, 411 and 415, all employees of all corporations which are members of a cont…
  16. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    lity for the excise taxes and that petitioner was liable for the additions to tax under section 6651(a)(1). Discussion I. Liability Under Section 4975 A. The Statutes Section 4975 was added to the Internal Revenue Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003…
  17. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    titioner husband's testimony concerning the legitimacy and amount of the business expenses was evasive and lacked credibility. For example, when asked whether he had brought documents to substantiate his business expenses, he responded that his documents were too numerous for him to find those respondent had requested …
  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. 62 T.C. 150; 62 T.C. No. 18 — Farley Funeral Home, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1974related by meaning
    he case of a partnership, is a partner who owns more than 10 percent of either the capital interest or the profits interest in such partnership. * * * Section 401 (d), which relates to pension trusts of unincorporated businesses, clearly does not apply to the pension trust here under consideration, which is a trust ope…