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83 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
  2. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
  3. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    , after holding that the taxpayer had no unpaid income tax for that year) ; Rowe v . Commissioner , T .C . Memo . 2001-325 (holding that the Court has jurisdiction to review the Commissioner's denial of section 6015(f) relief from additions to tax and penalties) . We hold that "taxes" in TRHCA section 408(c) includes t…
  4. Ann. 2007-47 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsMay 14, 2007
    …nt Co.) 700 SW Harrison Street Topeka, KS 66636-0001 8/14/1996 216. SG Cowen Securities Corporation 1221 Avenue of the Americas New York, NY 10020 6/30/1998 217. ShareBuilder Securities Corporation 1000 124th Avenue, NE Bellevue, WA 98005 4/15/2003 218. SMA Services, Inc. 35 Lakeshore Drive Birmingham, AL 35209 8/27/19…
  5. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
  6. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    …tion 1001.—See section 3.01(3), above. (52) Section 1036.—See section 3.01(33), above. (53) Section 1221.—Capital Asset Defined.—Whether specialty stock allocated to an investment account by a registered specialist on a national securities exchange is a capital asset. (54) Section 1239.—See section 3.01(32), above. (55…
  7. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  8. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  9. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005
    …es of the corporations are integrated. (48) Section 1036.—See section 3.01(31), above. (49) Section 1221.—Capital Asset Defined.—Whether specialty stock allocated to an investment account by a registered specialist on a national securities exchange is a capital asset. (50) Section 1239.—See section 3.01(30), above. (51…
  10. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  11. Ann. 2005-59 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsSep 12, 2005
    …nt Co.) 700 SW Harrison Street Topeka, KS 66636-0001 8/14/1996 210. SG Cowen Securities Corporation 1221 Avenue of the Americas New York, NY 10020 6/30/1998 211. ShareBuilder Securities Corporation 1000 124th Avenue, NE Bellevue, WA 98005 4/15/2003 212. SMA Services, Inc. 35 Lakeshore Drive Birmingham, AL 35209 8/27/19…
  12. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
  13. Ann. 2004-72 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsOct 12, 2004
    …) 700 SW Harrison Street Topeka, KS 66636-0001 August 14, 1996 203. SG Cowen Securities Corporation 1221 Avenue of the Americas New York, NY 10020 June 30, 1998 204. ShareBuilder Securities Corporation 1000 124th Avenue, NE Bellevue, WA 98005 April 15, 2003 205. SMA Services, Inc. 35 Lakeshore Drive Birmingham, AL 3520…
  14. Ann. 2003-54 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsOct 6, 2003
    …ent) 700 SW Harrison St. Topeka, KS 66636-0001 August 14, 1996 201. SG Cowen Securities Corporation 1221 Avenue of the Americas New York, NY 10020 June 30, 1998 202. SMA Services, Inc. 35 Lakeshore Drive Birmingham, AL 35209 August 27, 1998 203. Smith, Moore & Co. 400 Locust Street St. Louis, MO 63102 January 18, 1983 …
  15. ERISACode / StatuteJan 3, 2005
    The staffs of the Committee on Ways and Means and the Committee on Education and Labor of the House of Representatives, the Joint Committee on Taxation, and the Committee on Finance and the Committee on Labor and Public Welfare of the Senate shall carry out the duties assigned under this subchapter to the Joint Pension…
  16. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  17. T.C. Memo. 2012-300 — Churchill, LTD. Employee Stock Ownership Plan & Trust v. Commissioner
    IRCCourt RulingsOct 25, 2012related by meaning
    hall include compensation which is not currently includible in the Participant's gross income by reason of the application of sections 125, 402(a)(8), 402(h)(1)(B), or 403(b) of the Code, but shall not exceed $200,000 for any Plan Year. -15- [*15] In the second amendment to the 1989 plan the definition of "compensation…
  18. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010related by meaning
    le purposes, absent some constitutional defect we are constrained to apply the law as written, see Estate of Cowser v . Commissioner , 736 F .2d 1168, 1171-1174 (7th Cir . 1984), affg . 80 T .C . 783 (1983), and we may not rewrite the law because we may "deem its effects susceptible of improvement" ., Commissioner v . …
  19. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
  20. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…