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81. 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…
82. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …rld, Inc. v. Commissioner , 81 T.C. 184, 204-207 (1983), affd. in part, revd. in part, and remanded 752 F.2d 89 (4th Cir. 1985). Here, petitioners insist that the partnerships' contemplated gross profits, in terms of 15 or 20 percent "overrides" and 10 percent late fees, were reasonable and consistent with contemporary…
83. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015related by meaning
    to the Commissioner with respect to the additional tax under section 72(t) because that additional tax is a tax and not a penalty, addition to tax, or additional amount. El v. Commissioner, 144 T.C. (Mar. 12, 2015) _ 9 _ [*9] tioner's qualified retirement account, but Wachovia Bank, then a unit of Wells Fargo, with whi…