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78 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …e UTSA is promulgated by the Uniform Law Commission. S ee generally, Uniform Trade Secrets Act with 1985 Amendments, Nat'l Conference of Commissioners on Uniform State Laws, August 1985. UTSA has been adopted in some form by 48 states. New York and North Carolina are the exceptions. See “Trade Secrets Act.” Uniform Law…
  2. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  3. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    …he list of specific exceptions to tax set forth in section 72(t)(2). Swihart v. Commissioner , T.C. Memo. 1998-407. Moreover, unlike petitioners in the present case, the taxpayers in Larotonda never - 8 - received the funds and had no opportunity to avoid the 10-percent premature distribution penalty under former secti…
  4. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    ess., 1962-3 C.B. 261, 268-269. All of these rulings have been declared obsolete. Rev. Rul. 72-488, 1972-2 C.B. 649; Rev. Rul. 72-92, 1972-1 C.B. 408. Although petitioner does not directly argue that the regulation is void, it would, in effect, have us invalidate all of the regulations mentioned above. Because this Cou…
  5. 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
    …1995 158. Moseley, Hallgarten, Estabrook & Weeden, Inc. One New York Plaza New York, NY 10004 12/10/1985 159. Murphy Favre, Inc. W. 601 Riverside 9th Floor Spokane, WA 99201 8/2/1976 160. Mutual Service Cooperative Two Pine Tree Drive Arden Hills, MN 55112 6/6/1996 161. Myriad Corporation 1400 50th Street West Des Moin…
  6. Ann. 2006-45 — 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…
    IRCAnnouncementsJul 31, 2006
    …y Services, Inc. (Nationwide Financial Services, Inc.) One Nationwide Plaza Columbus, OH 43216 9/25/1985 162. Nationwide Credit Union One Nationwide Plaza Columbus, OH 43216 4/13/1978 163. NBC Securities, Inc. 1927 First Avenue North Birmingham, AL 35203 7/16/1996 164. Neuberger & Berman 522 Fifth Ave. New York, NY 100…
  7. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
  8. 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
    …y Services, Inc. (Nationwide Financial Services, Inc.) One Nationwide Plaza Columbus, OH 43216 9/25/1985 164. Nationwide Credit Union One Nationwide Plaza Columbus, OH 43216 4/13/1978 165. NBC Securities, Inc. 1927 First Avenue North Birmingham, AL 35203 7/16/1996 166. Neuberger & Berman 522 Fifth Ave. New York, NY 100…
  9. PLR 199934002 — Deferred Compensation
    IRCPrivate Letter RulingsAug 27, 1999related by meaning
    their vacations were paid an allowance in lieu of their vacations. In Tennessee Consolidated Coal Co. v. Comm'r. , 15 T.C. 424 (1950), a calendar 9 4 The ruling also cites Morrisdale Coal Mining Co. v. Comm'r. , 19 T.C. 208 (1952), Commissioner's appeal withdrawn , (3d Cir. 1955); and E.H. Sheldon & Co. v. Comm'r. , 1…
  10. T.C. Memo. 2017-132 — Jack Howard Taylor v. Commissioner
    IRCCourt RulingsJul 5, 2017
    …o another. Petitioner reads into this Court's precedent, see, e.g., Tateosian v. Commissioner, T.C. Memo. 2008-101; Mabry v. Commissioner, T.C. Memo. 1985-328; Wiedmaier v. Commissioner, T.C. Memo. 1984-540, aff'd, 774 F.2d 109 (6th Cir. 1985), a requirement that there be a clear, unambiguous formal transfer of a taxpa…
  11. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    … Judge v. Commissioner , 88 T.C. 1175, 1180-1181 (1987); Naftel v. Commissioner , 85 T.C. 527, 529 (1985). This Court's jurisdiction - 8 - to redetermine a deficiency in tax generally does not extend to statutory interest imposed under section 6601. See Bax v. Commissioner , 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an O…
  12. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
  13. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ear. * * *. Moreover, no deduction is allowed with respect to a dividend paid. [H. Conf. Rept. 99-841, at 11-276 (1986), 1986-3 C.B. (Vol. 4) 1, 276.] Accordingly, we find that the Commissioner acted within her delegation of authority, and that section 1.56(g)-1(d)(3)(iii)(E), Income Tax Regs., harmonizes with the reve…
  14. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
  15. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  16. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …iness use. Sec. 1.274-5T(c)(2)(i) and (ii), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). As pertinent here, section 1.274-5T(c)(3)(ii), Temporary Income Tax Regs., 50 Fed. Reg. 46021 (Nov. 6, 1985), entitled “Sampling”, provides a method of substantiation that a taxpayer may use if the taxpayer does n…
  17. 100 T.C. 216; 100 T.C. No. 15 — Halliburton Co. v. Commissioner
    IRCCourt RulingsMar 24, 1993related by meaning
    accordingly treated the number of IMCO transferees as 437. The parties agree that the forfeitures constituted only 4.8 percent of plan assets in 1986. We note that the Court of Appeals for the Third Circuit has indicated that a partial termination should be found only if the reductions in participation are so large tha…
  18. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    s. 601.201(a)(2) and (3), 601.201(1)(5), and 601.201(m), Statement of Procedural Rules; Myron v. United States, 382 F.Supp. 590, 597 (C.D. Cal. 1974). In analogous situations, when there have been similar material changes in the facts on which a ruling was based, the courts have upheld the Commissioner’s authority to r…