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81. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …ss income consisting of $5,704 of miscellaneous income for 2003 and $2,205 of other income and $176,495 of investment income for 2004. Mr. Warmoth filed his 2002-04 Forms 1040, U.S. Individual Income Tax Return." On his Forms 1040 Mr. Warmoth reported (1) passive income of $4,134 from Leading Edge for 2002; (2) nonpass…
82. 75 FR 64910 — Fiduciary Requirements for Disclosure in Participant-Directed Individual Account Plans
    ERISAFinal Rules (FR)Oct 20, 2010related by meaning
    l, part-time, or high turnover, and that revenue is too low or uncertain. See http://www.ebri.org/​surveys/​sers for more detail. Back to Citation 47.  It also is possible that rather than discouraging employers from sponsoring or continuing to sponsor a retirement plan, increased administrative burden could instead in…
83. T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner
    IRCCourt RulingsJul 29, 1997
    …ew York. The estate tax return was filed on January 2, 1990. It reported a total gross estate of $8,495,460. The estate claimed a marital deduction of $7,305,191, which consisted of $3,965,959 in property interests not subject to a QTIP election and $3,339,231 in property interests subject to a QTIP election. 1 Respond…
84. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …the business. Commissioner v. Heininger, 320 U.S. 467, 471 (1943); Deputy v. du Pont, 308 U.S. 488, 495 (1940). The evidence is unclear as to what Xcluseif's business actually entailed, and thus the Court has no way to determine which expenses are ordinary and necessary.. And even if petitioner demonstrated that the al…
85. ERISA § 403(b) (29 U.S.C. § 1103) — Establishment of trust
    ERISACode / StatuteJan 6, 2025related by meaning
    (b) (b) Exceptions The requirements of subsection (a) of this section shall not apply— (b)(1) (1) to any assets of a plan which consist of insurance contracts or policies issued by an insurance company qualified to do business in a State; (b)(2) (2) to any assets of such an insurance company or any assets of a plan whi…
86. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012
    …_ common or frequent occurrence in the type of business involved." Deputy v..du Pont, 308 U.S. 488, 495 (1940). An expense is necessary if it is appropriate and helpful for the business. See Commissioner v. Heininger; 320 U.S. at 471. Only the portion of an expense that is reasonable qualifies for deduction under secti…
87. ERISA § 4005(c) (29 U.S.C. § 1305) — Pension benefit guaranty funds
    PBGCCode / StatuteJan 6, 2025related by meaning
    (c) (c) Repealed. Pub. L. 112–141, div. D, title II, §40234(a), July 6, 2012, 126 Stat. 858