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81. 49 T.C. 174 — Armanco Productions, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1967related by meaning
    dic or annual compensation on the basis of permanent employment; (c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…
82. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
83. T.C. Memo. 1996-446 — Kay A. Clawson v. Commissioner
    IRCCourt RulingsSep 30, 1996related by meaning
    …tributee by any employees' trust described in section 401(a) which is exempt from tax under section 501(a) shall be taxable to him, in the year in which so distributed, under section 72 * * * More specifically, section 402(a)(9) provides: For purposes of subsection (a)(1) and section 72, any alternate payee who is the …
84. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    Eanes as petitioner. In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
85. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    e within the parameters spelled out in section 404(a)(6), may be deducted in the prior year, but only if they fall within the deduction limitations of section 404(a) and related subsections. Since petitioner's Motion and the Judicial Notice Motions never address this allimportant proviso, petitioner's claim, even if co…
86. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…
87. T.C. Memo. 2011-2 — Michael C. Hollen, D.D.S., P.C. v. Commissioner
    IRCCourt RulingsJan 4, 2011related by meaning
    …or a.trust to be considered a qualified trust entitled do preferential tax- treatment-under section 501(a). See generally Ronald R. Pawlak, P-.C. v. ,Commissioner, T.C. Memo. 1995-7 (discussing the types of preferential tax treatment:under section 501(a)). In addition, 'the Employee Retirement Income Security Act of 19…
88. T.C. Summary Opinion 2016-40 — Paul Parisi v. Commissioner
    IRCCourt RulingsAug 9, 2016related by meaning
    on 72(t)(2)(E) applies to him. Respondent argues that petitioner failed to establish that he had qualified higher education expenses for 2011. For the reasons set forth below, we agree with respondent. Section 72(t)(1) imposes a 10% additional tax on the taxable amount of an early distribution from a qualified retireme…