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81. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    …r exchanged as required by the Court's pretrial order. See G.J.B. & Associates, Inc. v. Singleton , 913 F.2d 824, 831 (10th Cir. 1990). In the Singleton case, the plaintiffs had not exchanged discoverable documents as required by the Court's pretrial order and sought to use the documents to refresh a witness' memory. T…
82. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    etitioner does not cite any relevant law to establish her position. We similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of section 61, that all income is taxable unless explicitly excluded. See Baldwin v. Commissi…
83. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980
    …4 11 3.75:1 1/5 /70 15 1 3 4 11 3.75:1 1/4 /71 13 1 3 4 9 3.25:1 1/3 /72 14 1 3 4 10 3.50:1 1/14/73 913 4 5 2.25:1 Column 5 in the above table shows, in absolute terms, that the Higgins Plan participants had 14 percent more of their salaries contributed in the first 6 months of 1968; and 11 percent more in the last 6 m…
84. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
85. 78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans
    IRCFinal Rules (FR)Dec 26, 2013
    …vided by the Bureau in connection with promulgation of the supplemental final rule, approximately 5,913 commercial banks and savings institutions, 3,784 credit unions, and 2,672 non-depository institutions are considered small entities and extend mortgages, and therefore are potentially subject to the January 2013 Fina…
86. 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).…
87. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    ot entitled to IRA contribution deductions because they did not substantiate their IRA deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial understatement of income tax. Discussion In general, the determinations of the Commissioner in a notice of de…
88. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …3 20,155 19,125 18,162 233,488 −Baseline 29,273 27,609 26,066 24,636 23,310 22,082 20,944 19,890 18,913 18,009 230,732 = Benefits −26 237 398 433 390 365 329 265 211 153 2,756 Present Value of Benefits by Discount Rate: 3 Percent −26 224 364 385 337 306 267 209 162 114 2,342 7 Percent −25 207 325 331 278 243 205 154 11…
89. T.C. Summary Opinion 2004-29 — Howard T. Owens, Jr. & Ann E. Owens v. Commissioner
    IRCCourt RulingsMar 15, 2004related by meaning
    t 22, 2001, respondent issued to petitioners a notice of deficiency determining that they were liable for this additional tax in the amount of $2,000. Discussion I. General Rules In general, section 408 governs the treatment of IRAs. Specifically, section 408(d) provides that distributions from an IRA are taxable in th…