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81. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    se cases. To the contrary, petitioners' supplement informs the Court that "[p]etitioners agree with Respondent that the arrangements were entered into after September 17, 2003", for purposes of sec. 1.61-22, Income Tax Regs. Petitioners in their opening brief now invite the Court to decide whether the life insurance ar…
82. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    IRCCourt RulingsSep 24, 2026
    …vering v. Taylor, 293 U.S. 507, 515 (1935)); see Texasgulf, Inc., & Subs. v. Commissioner, 172 F.3d 209, 214 (2d Cir. 1999), aff’g 107 T.C. 51 (1996). 3 The documentary record establishes tha t petitioner d uring 2021 made transfers from his E*Trade IRA to two separate accounts: his E*Trade brokerage account and his We…
83. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
84. 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…
85. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    … of section 6651(a)(2). Sec. 6651(g)(2); see also, e.g., Wheeler v. Commissioner, 127 T.C. 200, 208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). Respondent has the burden to prove that substitutes for returns satisfying the requirements of section 6020(b) were submitted. See Cabirac v. Commissioner, 120 T.C. 163,…
86. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    d. Reg. 17775), dated May 13, 1993 (58 Fed. Reg. 28446), dated May 18, 1993 (58 Fed. Reg. 28921).” In our view, while the first correction related 214 to both the 1993 temporary regulation and the 1993 notice of proposed rulemaking, the second and third corrections related only to the 1993 temporary regulations. They d…
87. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …ted that. the transfer was defined by the gift tax statutes as a gift. The Revenue Act of 1932, ch. 209, sec. 503, 47 Stat. 247,'provided that "Where property- is transferred for:less than an adequate and full consideration in money or money's worth, then the amount by
88. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979related by meaning
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
89. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …t through which income flows to . its shareholders . See Gitlitz v . Commissioner , 531 U .S . 206, 209 (2001) ("Subchapter S allows shareholders of qualified corporations to elect a `pass-through' taxation system under which income is subjected to only one level of taxation .") . A qualifying "small business corporati…
90. T.C. Memo. 2003-157 — Susan L. Rosetti v. Commissioner
    IRCCourt RulingsMay 28, 2003
    …2002). FINDINGS OF FACT On her timely filed 1998 Federal income tax return, petitioner reported $43,209 in wages, claimed a $2,000 IRA deduction, and elected married filing separately status. On June 22, 2001, respondent disallowed the deduction and determined a $574 deficiency. During 1998, petitioner was a real estat…
91. 81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    under section 4975 of the Code] is hereby transferred to the Secretary of Labor”). Back to Citation 9.  29 CFR 2550.408b-2(e); 26 CFR 54.4975-6(a)(5). Back to Citation 10.   See PTE 86-128, Exemption for Securities Transactions Involving Employee Benefit Plans and Broker-Dealers, 51 FR 41686 (November 18, 1986), as ame…