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81. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    ….” (260 F.2d at 13.) We agree with the recent statement in Edwin’s, Inc. v. United States, 501 F.2d 675, 679 (7th Cir. 1974), affg. in part and revg. and remanding in part 355 F. Supp. 773 (W.D. Wisc. 1972), “pension payments constitute compensation which must be considered in determining whether the total compensation…
82. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…
83. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989
    …um of both employee and employer contributions (see, e.g., Edwin’s, Inc. v. United States, 501 F.2d 675, 679 (7th Cir. 1974)), or (3) the then present value of the employee’s right to retirement benefits to be paid at a later date (see sec. 457(d)(6)). See Concord Consumers Housing v.
84. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    portion of the distribution reported as taxable income on the Form 1099-R ($25,709). Respondent further determined that the 10-percent additional tax imposed by section 72(t) applied to this amount, and that petitioners were liable for a negligence penalty pursuant to section 6662(a). OPINION Savings Plan Distribution…
85. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977
    … 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. Feroleto, Jr. 4,180.39 3,265 Seaboard stayed in business until 1975, when it became bankrupt and ceased to operate. Frank Y. Feroleto be…
86. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    ith respect to our Opinion. In our Opinion, we held that petitioner may not deduct in a single taxable year contributions to 29 collectively bargained defined benefit plans made over a period of 20 (in some cases 19) months. In the Motion petitioner alleges that the Court erred in that this holding contradicts 20 years…
87. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    …mall employer Individual Total Under $250,000 15,000 225,000 38,000 278,000 $250,000-499,999 45,000 675,000 115,000 835,000 $500,000-999,999 60,000 900,000 153,000 1,113,000 $1,000,000-1,999,999 2,389,000 2,869,000 1,177,000 6,435,000 $2,000,000 plus 6,041,000 2,869,000 377,000 9,287,000 Total 8,550,000 7,538,000 1,860…
88. T.C. Summary Opinion 2003-153 — Joseph Jones v. Commissioner
    IRCCourt RulingsOct 20, 2003related by meaning
    the 1999 distribution from TESPHE, petitioner had not reached age 59½ and was not disabled. Fidelity issued to petitioner a Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., showing a gross and taxable distribution from his TESPHE account for 1999 …
89. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…