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77 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    but before the due dates of the returns as extended. 1. Held : pension contributions, based on units of service worked after the close of TYE 8801 and before Oct. 17, 1988, were not on account of P's TYE 8801, as required by sec. 404(a)(6), I.R.C., and are therefore not deductible in that year. Lucky Stores, Inc., & Su…
  2. 78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-…
    IRCFinal Rules (FR)Nov 13, 2013
    …$194.2 $194.2 $194.2 $699.2 2015 208.4 4.3 212.7 206.5 198.8 732.0 2016 226.8 4.3 231.1 217.9 201.9 764.8 2017 245.3 4.3 249.6 228.4 203.7 797.6 2018 263.8 4.3 268.1 238.2 204.5 830.4 Total 1,134.2 21.5 1,155.6 1085.1 1,003.1 3,824.0 1. Estimated Number of Affected Entities MHPAEA has already brought about coverage cha…
  3. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    by section 404(a)(6), and are therefore not deductible in that year. To reflect the foregoing and issues previously resolved, Decision will be entered under Rule 155 .
  4. 102 T.C. 499; 102 T.C. No. 17 — Janpol v. Commissioner
    IRCCourt RulingsMar 28, 1994
    … with the section 6651(a)(1) addition to tax in Knollwood Memorial Gardens v. Commissioner, 46 T.C. 764, 794 (1966). In that case, we held that, although a taxpayer’s good faith belief that it was a tax-exempt entity was sufficient to permit its Form 990 return to start the running of the period of limitations, such a …
  5. 88 T.C. 641; 88 T.C. No. 35 — Calfee, Halter, & Griswold v. Commissioner
    IRCCourt RulingsMar 23, 1987related by meaning
    g, Decisions will be entered for the petitioners. By order of the Chief Judge, these cases were reassigned to Judge Williams for decision and opinion. All section references are to the Internal Revenue Code of 1954 as amended and in effect during the years in issue, unless otherwise indicated. The statutory prerequisit…
  6. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    rough prosecution of a legal suit or action based upon tort or tort type rights, or - 14 - through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 65…
  7. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004related by meaning
    f. United States v. Boyle , supra at 249 (taxpayers have a personal and nondelegable duty to file a timely return; reliance on an accountant to file a return does not provide reasonable cause for an untimely filing). We hold that petitioner is liable for the section 6651(a)(1) additions to tax respondent determined. - …
  8. U.S. Tax Court — Daryl L. Koelemay v. Commissioner
    IRCCourt RulingsSep 2, 2009related by meaning
    T .C . Summary Opinion .2009=i3 4 UNITED-STATES TAX COUR T DARYL L . KOELEMAY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 24773-08S . Filed September 2, 2009 . Daryl L . Koelemay, pro s e Ardney J . Boland III , for respondent . JACOBS, Judge : This case was heard pursuant to the provision…
  9. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  10. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  11. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  12. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross income rental income of $4,920 they received in 2007. - 3 - [*3] to deduct a net operating loss (…
  13. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    e funds ) . 14 [* 14] Moreover, we disagree with petitioner that Larotonda was abrogated by the repeal of section 72(m)(4). Former section 72(m)(4)(A) was replaced by section 72(p) (1)(B), which is substantially similar to section 72(m)(4)(A). 7 In addition, this Court has continued to cite Larotonda as binding precede…
  14. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan. Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
  15. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    6212(a), nor do we question whether respondent has issued valid statutory notices of deficiency. Compare Scar v. Commissioner, 814 F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855 (1983). As we embark upon the Odyssey mandated by the interrelationships and cross-references of section 4975 and the applicable provisions of t…
  16. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…