Search the Pension Law Library

81. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    me day respondent issued to petitioner a notice and demand for payment of the unpaid interest . On or about July 25, 2000, petitioner filed Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief ), requesting section 6015 ( f) equitable relief from the unpaid interest . More tha…
82. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. Both sides have dealt with the status of the 32-page document as a tax return but only for purposes of the sec. 6651(a) issue presented to us. Under the circumstances, w…
83. Treas. Reg. § 54.4975-14(c) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (c) (c) Method of election. A person shall make the election referred to in this section by filing the form issued for such purpose by the Internal Revenue Service, including therein the information required by such form and the instructions issued with respect thereto, and by paying the tax which the taxpayer indicate…
84. 63 T.C. 255; 1 Employee Benefits Cas. (BNA) 1135 — Harwood Associates, Inc. v. Commissioner
    IRCCourt RulingsNov 26, 1974
    …Commissioner, 35 F.2d 910 (C.A. 6, 1929), affirming 8 B.T.A. 628 (1927), certiorari denied 281 U.S. 735 (1930). Although a plan of deferred compensation may not qualify under section 401(a), an employer may nevertheless be entitled to claim deductions by reason of his having contributed to a trust established pursuant …
85. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    sonable compensation and therefore not deductible under section 162 (and thereby section 404), the 10% section 4972 excise tax applies to that extent. V. Section 6651(a)(1) and (2) Additions to Tax Respondent contends that the corporation is liable for section 6651(a)(1) failure to file additions to tax of $10,050.95 a…
86. 71 T.C. 1049 — Minnis v. Commissioner
    IRCCourt RulingsMar 26, 1979
    …ited States, 215 Ct. Cl. 840, 572 F.2d 826 (1978). But see Carpenter v. Commissioner, 322 F.2d 733, 735 (3d Cir. 1963), affg. a Memorandum Opinion of this Court, a case which involved a transaction considered to be without economic substance under the rationale of Knetsch v. United States, supra.
87. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014related by meaning
    sfy the standards set forth in section 6330. See secs. 6320(b)(4), 6330(c). As a preliminary matter we note that although the petition in this case is entitled "Petition for Redetermination of Lien or Levy Action under Code Section 6320 and/or 6330(d)", our jurisdiction is limited to the review of the levy action pursu…
88. 89 T.C. 225; 89 T.C. No. 19 — Professional & Executive Leasing v. Commissioner
    IRCCourt RulingsAug 3, 1987
    …ative record. Tamko Asphalt Products, Inc. v. Commissioner, 71 T.C. 824, 837 (1979), affd. 658 F.2d 735, 738-739 (10th Cir. 1981); Rule 217(a). To determine the existence of an employer-employee relationship we must look to common law concepts. See Edward L. Burnetta, O.D., P.A. v. Commissioner, 68 T.C. 387, 397 (1977)…
89. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977
    …oration for the years indicated: 1970 1971 Frank Feroleto.$15,080.20 $7,500 Helen Feroleto.2,693.59 735 Arthur J. Croteau. 965.19 0 Orville Powell.1,104.15 1,184 George Evanchick. 988.51 0 Chris Kiosse. 681.67 0 Marguerite Kiosse. 675.94 400 Lawrence Varholak. 1,174.89 1,020 Thomas Dunn. 1,169.58 1,115 Francis V. Ferol…
90. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
91. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
92. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …85, 134. 22 50% of net income_ 42, 567. 11 15% of gross income_ 25, 874. 20 5% of gross income_ 18, 735. 98 Total percentage depletion_ 44, 610. 18 Allowable depletion — Corona_ 42, 567.11 Allowable depletion — Pacific Grove-42,137. 51 Total depletion allowable on sand__ 84, 704. 62 Claimed on return— Corona_ $27, 360.…
93. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
94. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …fting the documentation. This results in an estimated cost of approximately $41.3 million annually.[735] Costs Associated With the Provision of Disclosures to Retirement Investors
95. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    husband only. The notices of deficiency also determined accuracy-re lated penalties under section 6662, but respondent has conceded the penalties . 3 [* 3 ] After a corporate reorganization in 2004, TEOHC informed petitioner that it wished to buy out his interests. Following lengthy negotiations , TEOHC a greed to pay…