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93 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 78 T.C. 86; 78 T.C. No. 6 — Horvath v. Commissioner
    IRCCourt RulingsJan 20, 1982related by meaning
    ee also Bogaards v. Commissioner, T.C. Memo. 1981-540; Boykin v. Commissioner, T.C. Memo. 1981-447. Cf. Alexander v. Commissioner, T.C. Memo. 1980-71. Petitioners have strenuously argued that the contribution to the IRA was deductible, while ignoring the inclusion by respondent of the income credited to the IRA in thei…
  2. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    ................................. 9 MIT 80.................................................. 12 Formation of MIT 80................................ 12 Investors in MIT 80................................ 13 Organization and Management of MIT 80.............. 13 MIT 80 Employee Leasing Arrangement................ 14 Oper…
  3. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971
    …his Court. In response Congress enacted section 44(d) of the Keren.ue Act of 1928, 45 (pt. 1) Stat. 806, which was designed to terminate the privilege of reporting gain on the installment method where a taxpayer who had elected installment method treatment subsequently disposed of unpaid installment obligations. The Ho…
  4. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010related by meaning
    from qualified retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C . Memo . 2 .005-124 (education expenses paid from a section .401(k)_ plan do not qualify for the exception . of ,section 72(t) (2) (E))- ; Milner v . Commissioner , T .'C .` .Memo . 2004-111 (no "umbrell a hardship exception" .for a distr…
  5. 85 FR 40834 — Improving Investment Advice for Workers & Retirees
    ERISAProposed Rules (FR)Proposed Jul 7, 2020
    …f the business. This results in an hour burden of 4,340 [166] and an equivalent cost burden of $718,806.[167] The Department welcomes any comments about burden hours associated with producing an annual review report and certifying it. Overall Summary Overall, the Department estimates that in order to meet the condition…
  6. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    t to "a former spouse * * * who is recognized by a domestic relations order as having a right to receive" a share of the proceeds. See sec. 414(p)(8). Second, the distribution was not made "pursuant to a qualified domestic relations order." Although Jeremy's petition for dissolution of marriage requested a 50-50 divisi…
  7. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
  8. 84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans
    IRCFinal Rules (FR)Jun 20, 2019
    … (a) (b) (c) (d) (e) = (c) * (d) 2020 634,155 291,711 $0.30 $87,513 2021 1,556,562 716,019 0.30 214,806 2022 3,055,474 1,405,518 0.30 421,655
  9. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975
    …Docket No. Petitioner Year Deficiency 524-73 Ronald C. Packard and 1968 Roma Jean Packard 1969 $696 806 525-73 Floyd L. Packard and 1968 Alice E. Packard 1969 618 760 526-73 H. Von Packard 1968 305 Sheila D. Packard 1968 308 H. Von Packard and Sheila D. Packard 1969 626 The' sole issue presented for decision is whether…
  10. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    ented are contained in pleadings and other documents in the record, and are not controverted. We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's 1991 taxable year. If respondent was not entitled to do so, then the August notice would not be valid as…
  11. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …61.00 5,303.00 12/31/87 2,647.00 12/31/88 1,802.00 15473-91 12/31/87 8,105.00 $2,026.25 12/31/88 10,806.00 2,701.50 Arizona Orthopedic Institute of Traumatic and Reconstructive Surgery, P.C. 19654-90 04/30/87 139,909.00 32,699.00 12/31/87 45,507.00 2,623.00 Jonathan R. and Renee K. Fox 19716-90 12/31/86 13,750.00 4,125…
  12. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990
    …691 1,564 174 Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $181,806. Although petitioners’ motion suggests that we lack jurisdiction over years closed by the applicable limitations period, we have jurisdiction over such years, as the statute of limitations is an affirmative defense t…
  13. TR 2026-01 — Technical Release 2026-01
    ERISADOL Technical ReleasesApr 1, 2026
    …e out ERISA plans for special treatment. De Buono v. NYSA-ILA Med. & Clinical Servs. Fund, 520 U.S. 806, 814-15 (1997) (collecting cases). But conversely, the Supreme Court has held that ERISA does not preempt laws that require one-time severance payments,(16) PBM rate reimbursement regulations with only incidental eff…
  14. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    T.C. Memo. 1997-346 UNITED STATES TAX COURT WILLIAM L. REESE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18442-95. Filed July 29, 1997. 1. Held : P is taxable on a pension plan distribution because he failed to roll over that distribution within the 60-day period prescribed by sec. 402(a)(5)…
  15. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    him . On May 24, 2002, SBC Communications, Inc ., issued a check to petitioner in the amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and $3,367 .11 in California State income tax had been withheld . During 2002, petitioner also received $9,552 …
  16. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    treated as a gift, dividend, contribution of capital, payment of compensation, or other payment depending on the substance of the transaction. Section 7872 applies to a transaction that is a loan subject to a belowmarket interest rate and is described in one of several enumerated categories. Sec. 7872(c) (1), (e) (1), …
  17. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    fits fall under section 104 , or any other specific statutory exclusion , Mr. Tuma instead seems only to have argue d for a general exclusion based on disability for which he provides no support in the Code and for which we have found none . 11 We have previously held both railroad retirement and Social Security benefi…
  18. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    ave specified, petitioner’s arrangements were vague and did not provide the employees with nonforfeitable rights to particular portions of the moneys. In reliance on the above, it follows that section 404(b) is inapplicable to petitioner, and accordingly, petitioner cannot deduct the $16,123 “contribution” pursuant to …
  19. 71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner
    IRCCourt RulingsMar 19, 1979related by meaning
    section 404(a)(7) and section 1.404(a)-13, Income Tax Regs., is reasonable and wé refuse to hold it invalid. Decision will be entered under Rule 155. Petitioner has also agreed to an adjustment to its taxable income made by respondent for forfeitures not properly offset by petitioner against its allowable pension plan…
  20. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    ition is logically inconsistent to the extent that it continues to treat the loan as - 27 - outstanding for purposes of section 72(p) despite the fact that the principal amount of the loan previously has been deemed distributed and included in the taxpayer's income under section 72(p). Furthermore, respondent cites no …