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81. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    T.C. Memo. 1998-203 UNITED STATES TAX COURT RAMON A. GARCIA AND BERTHA E. GARCIA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21532-95. Filed June 3, 1998. Richard M. Taylor and James E. McCutcheon III , for petitioners. Elizabeth A. Owen , for respondent. MEMORANDUM FINDINGS OF FACT AND OPI…
82. T.C. Memo. 2013-124 — Kenneth A. Carter, Robert J. Kurek, John McFawn, Paul L. Miles, Adolph F. Rivas, Curlee Thomas, and Q.C. Williams, Jr.; Petitioners v. Commissioner of Internal…
    IRCCourt RulingsMay 9, 2013
    …Atkinson v. Commissioner, T.C. Memo. 2012-226, at *17 (citing Blanton v. Commissioner, 94 T.C. 491, 496 (1990)). It is clear from the record that the issue before us was "actually and necessarily determined" by the District Court and the Court of Appeals. See 6 As to petitioners' request in their petition that we "rein…
83. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
84. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
85. 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…
86. 29 C.F.R. § 2570.135 — Consent order or settlement.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
87. U.S. Tax Court — John R. Kirkpatrick v. Commissioner
    IRCCourt RulingsFeb 22, 2018
    …plishment and execution of congressional purposes and objectives. See English v. General Elec. Co., 496 U.S. 72, 79 (1990). Accordingly, to the extent that a State court's dictates conflict directly with Federal tax law, the former must - 14 - [*14] yield to the latter. See, e.g., Burnet v. Harmel, 287 U.S. 103, 110 (1…
88. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
89. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …ral income tax_ $12, 799. 00 Federal insurance contribution_ 2, 088. 90 Miscellaneous_ 608. 89 $15, 496. 79 Accounts payable_ 79, 804. 88 Accruals:
90. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004related by meaning
    er, 88 T.C. 1474 (1987), the taxpayer sold stock to the employees' pension trust of the professional corporation that he owned. The taxpayer contended that the trust's purchase "would qualify as a prudent investment if judged under the highest fiduciary standards." Id. at 1477. We concluded on that issue as follows: Af…