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77 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    …965_ 38,039 38,039.00 1966_ 53,246 53,246.00 1967_ 62,450 62,450.00 1968_ 72,735 72,735.00 1969_ 75,702 75,702.00 1970: 1/1 -11/23_ 81,473 11/23 — 11/30 _ $923.08 $16,469.88 102,558.28 12/1 -12/31_ 3,692.32 1971_ 48,000.16 17,023.82 65,023.98 1972_ 48,223.24 16,003.16 64,226.40 1973_ 48,000.16 16,900.24 64,900.40 1974_…
  2. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    for tax-free rollover treatment under section 402(a)(5). The resolution of this issue turns on whether the distribution constitutes a "qualified total distribution" as defined by section 402(a)(5)(E)(i). If we conclude that the distribution in question does not qualify for tax-free rollover treatment, then we must also…
  3. 37 T.C. 817 — Wasatch Chemical Co. v. Commissioner
    IRCCourt RulingsJan 24, 1962
    …made its contribution for 1956 by delivering to the trust its promissory note in the amount of $36,-702.93. This note was also unsecured, bore interest at the rate of 6 percent per annum, and was to mature on March 1, 1962. This note was discharged on December 8, 1958. In filing its Federal corporation income tax retur…
  4. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  5. IRCCourt RulingsOct 4, 1979
    …on his individual return his distributive share of partnership income and expenses pursuant to sec. 702. Reasoning by analogy, respondent argues that we should ignore the partnership entity and attribute the partnership employees to the individual partners regardless of their ownership interest. However, this argument …
  6. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
  7. 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…
  8. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    or lack of jurisdiction. Appropriate orders will be issued. Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
  9. T.C. Summary Opinion 2024-10 — Edward George Shlikas v. Commissioner
    IRCCourt RulingsJun 20, 2024related by meaning
    n IRA or an annuity as defined in section 408(a) and (b). See § 7701(a)(37). 5 Respondent argues that on the basis of the deed dated November 9, 2019, petitioner had an ownership interest in the property before the purchase of his brother’s share on December 5, 2019. See § 72(t)(8)(D)(i). Since we conclude that the dis…
  10. 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…
  11. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979related by meaning
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
  12. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    023.94 81,023.94 81,023.94 81,023.94 64,819.15 For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…
  13. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  14. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    int bank account. Finally, he emphasizes his history of paying his income tax from 2002 through 2015. 4 [* 4 ] Discussion I. Summary Judgment Standard The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1…
  15. 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…
  16. 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 …
  17. 89 T.C. 939; 89 T.C. No. 65 — Estate of Neisen v. Commissioner
    IRCCourt RulingsOct 28, 1987related by meaning
    under sec. 2056, I.R.C. 1954. James O. Ramstad, for the petitioner. Gail K. Gibson, for the respondent. Sterrett, Chief Judge. * STERRETT *939 OPINION By notice of deficiency dated January 3, 1986, respondent determined a deficiency in petitioner's Federal estate tax in the amount of $ 127,065.68. Due to concessions by…