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95 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-90 — Juanita Doby v. Commissioner
    IRCCourt RulingsMay 25, 2006
    …iciency is presumed correct. Welch v. Helvering , 290 U.S. 111, 115 (1933). In pertinent part, Rule 142(a)(1) provides the general rule that “The burden of proof shall be upon the petitioner”. In certain circumstances, however, if the taxpayer introduces credible evidence with respect to any factual issue relevant to a…
  2. U.S. Tax Court — Timothy D. Nelson v. Commissioner
    IRCCourt RulingsAug 16, 2010
    …correct, and the taxpayer bears the burden of proving that the determination is in error . See Rule 142(a) ; Welch v . Helvering , 290 U .S . 111, 115 (1933) . Pursuant to section 7491(a), the burden of proof as to,factual matters shifts to the Commissioner under certain circumstances . Petitioner has neither alleged t…
  3. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-29 Rev. Rul. 2007-29 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007. Announcement 2007-44 Announcement 2007-44 This anno…
  4. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010
    …epresents payment for- ;physical :injuries . The burden of-proof ; is on petitioner .' { See'_ Rule 142 ( a ) On brief, -although` he concedesx«that° he "bears the burden of proving respondent' s . determinationto-be erroneous", petitione r 'Petitioner has not claimed or shown that he meets the requirements under sec .…
  5. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsMar 3, 2000related by meaning
    DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 October 15, 1999 Number: 200009002 Release Date: 3/3/2000 CC:EBEO:4 TL-N-4712-99 UILC: 419.00-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizatio…
  6. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    atio = 1.47 × (1,400,000/10,509,091) = 0.196 = 19.6 percent. Proposed Revocation of Parts I(b), I(c) and II(2) of PTE 75-1 and Restatement of PTE 75-1 The Department is proposing to revoke Parts I(b), I(c) and II(2) of PTE 75-1. In connection with the proposed revocation of Part II(2), the Department is republishing Pa…
  7. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006related by meaning
    nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A). (48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
  8. T.C. Memo. 2015-244 — Jeremiah J. O'Connor & Mary K. O'Connor v. Commissioner
    IRCCourt RulingsDec 16, 2015
    …as the amount of the penalty, $28,483, is exactly 20% of the notice's determined tax deficiency of $142,416. B. Applicable Law Section 6662(a) and (b)(1)-(3) provides for an accuracy-related penalty (the penalty) in the amount of20% of the portion of any underpayment attributable to, among other things, negligence or i…
  9. 63 T.C. 267 — Cohen v. Commissioner
    IRCCourt RulingsNov 26, 1974related by meaning
    o him under the provisions of section 165(b), I.R.C. 1939, which contained provisions comparable to those of section 402(a), until distributed to him. In the Megibow case we stated in part (21 T.C. at 199-200):
  10. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …presumed correct, and the taxpayer bears the burden of proving those determinations erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioners contend that respondent bears the burden of proof for two reasons: (1) they have satisfied the requirements of section 7491(a) for shifting the burden of …
  11. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987related by meaning
    of employee benefit plans, and by providing for appropriate remedies, sanctions, and ready access to the Federal courts. [ERISA sec. 2, 88 Stat. 832.] We have stated above that in enacting section 4975(c)(1), Congress intended to create a blanket prohibition against certain transactions, regardless of how prudent the t…
  12. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  13. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  14. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
  15. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014
    142 T.C. No. 21 UNITED STATES TAX COURT WHISTLEBLOWER 11332-13W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11332-13W. Filed June 4, 2014. Whistleblower W reported a tax fraud scheme, involving W's employer and related entities, to the Government. W provided the Government with information re…