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81. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    spouse, child, or other dependent of a participant, and (ii) is made pursuant to a State domestic relations law (including a community property law). “The reason that many ERISA sections have such counterparts in the IRC is that, to encourage employers to establish pension plans, Congress provides favorable tax treatme…
82. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …s, P.C. v. Wells , 538 U.S. 440, 444-445 (2003); Nationwide Mut. Ins. Co. v. Darden , 503 U.S. 318, 322-323 (1992); Weber v. Commissioner , 60 F.3d 1104, 1110-1111 (4th Cir. 1995), affg. 103 T.C. 378 (1994); Air Terminal Cab, Inc. v. United States , 478 F.2d 575, 578 (8th Cir. 1973); Profl. & Executive Leasing, Inc. v.…
83. 81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    with respect to transactions involving IRAs. Section I(c)(1) provides that the exemption in Section I(a) does not apply if (A) the plan is an IRA [18] and (B) the fiduciary engaging in the transaction is a fiduciary by reason of the provision of investment advice for a fee, as described in Code section 4975(e)(3)(B) an…
84. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Act, 2001, Pub. L. 106-554, sec. 314(f), 114 Stat. 2763A-643 (2000) to confer jurisdiction to determine "the proper amount of employment tax." - 14 - economy and convenience to the parties, it was illogical for the Tax Court to have ju isdiction over worker classification but not over employment taxes assessed as a re…
85. T.C. Memo. 2005-5 — Thomas G. Wright and Estate of Rosemary K. Wright, Deceased; Thomas G. Wright, Personal Representative v. Commissioner
    IRCCourt RulingsJan 13, 2005
    … litigated and necessary to the outcome of the first suit. Parklane Hosiery Co. v. Shore , 439 U.S. 322 (1979). Furthermore, - 21 - the doctrine of collateral estoppel only forecloses relitgation of an issue previously litigated and decided in a prior suit. Id. at 326 n.5; United States v. Intl. Bldg. Co. , 345 U.S. 50…
86. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …. , 545 U.S. 967, 986 (2005); see also Ohio Periodical Distrib s ., Inc. v. Commissioner , 105 F.3d 322, 326 (6th Cir. 1997) , aff’g T.C. Memo. 1995- 496. And we defer to the agency’s interpretation unless it is “arbitrary, capricious, or manifestly contrary to the statute.” Chevron , 467 U.S. at 843– 44; see also Mayo…
87. T.C. Summary Opinion 2015-13 — Gustavo E. Morles v. Commissioner
    IRCCourt RulingsFeb 23, 2015related by meaning
    ng in section 72 suggests that such an exclusion exists, and we are aware of no other provision of the Internal Revenue Code that would allow for one. Although we sympathize with petitioner, we agree with respondent that the entire plan distribution is includable in petitioner's 2010 income under section 72(a) and (e).…
88. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    ent with the intent of DEFRA, and because it permissibly fills a gap created by sections 419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is not impermissibly broader than sections 419 and 419A and, accordingly, we hold that it is valid. Chevron…
89. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    rom the proceeds of the life insurance contract. See generally Cadwell v. Commissioner, 136 T.C. 38, 63-64 (2011), aff'd, 483 Fed. Appx. 847 (4th Cir. 2012). Section 1.61-22, Income Tax Regs., is effective for split-dollar life insurance arrangements entered into after September 17, 2003, and an arrangement that is "ma…