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1. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsJan 17, 2024related by meaning
   Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …rm Credit Admin. , 336 F.3d 1075, 1080 (D.C. Cir. 2003) (quoting Am. Mining Cong. v. EPA , 907 F.2d 1179, 1188 (D.C. Cir. 1990)). Petitioner has identified
3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   by the decision of the Tax Court which has become final shall be assessed and shall be paid upon notice and demand from the Secretary .”). In short, 5 For a discussion of the disputed issues of fact on this point, see the Order issued by the Court on April 8, 2019, denying each party’s Motion for Partial Summary Judgme…
4. 111 T.C. No. 15 — John F. Romann v. Commissioner
   IRCCourt RulingsNov 4, 1998
   …e Labor and Public Welfare Committee. The substitute embodied elements of S. 4, as reported, and S. 1179, as reported. In particular, section 601(a) of the substitute includes precisely the same language as section 601(a) of S. 1179, relating to declaratory judgment actions brought by employees. On September 19, 1973, …
5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
6. T.D. 9470 — Final regulations under section 6039 of the Code require corporations to file an information return with the IRS and furnish a written statement to each employ…
   IRCTreasury DecisionsDec 7, 2009
   …ubmitting substitute Forms 3921 and 3922 in accordance with the guidelines set forth in Publication 1179 (or its designated successor). For example, it would be permissible for a taxpayer to satisfy the return requirements of §1.6039-1(a) and (b) by submitting Forms 3921 and 3922 to the IRS, and satisfy the information…
7. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
   IRCCourt RulingsApr 26, 2005
   …endments to this Court's Rules in respect of declaratory judgments under section 7476, 64 T.C. 1177-1179 (1975). Consistent with this legislative intent, the Court has previously
8. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003related by meaning
   ks to collect the 10-percent additional tax on early distributions from qualified retirement plans. Once again, other than his self-serving testimony, petitioner has offered no evidence in support of his position, no bank statements or other evidence that would corroborate his assertion that the tax was withheld or tha…
9. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
   ERISAProposed Rules (FR)Proposed Mar 31, 2026
   …mize risk.” (citations omitted)). Back to Citation 36.   See Pizarro v. Home Depot, 111 F.4th 1165, 1179-80 (11th Cir. 2024) (rejecting a claim of failure to prudently monitor investments, stating, “[a] few here-and-there years of below-median returns, however, are not a meaningful way to evaluate a plan's success as a…
10. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
11. Court of Appeals for the Eleventh Circuit — Ann Johnson v. Russell Investments Trust Company
    ERISACourt RulingsAug 17, 2026
    … assess its objective prudence, grouping them in qualitative and quantitative buckets , s ee id. at 1179 – 82. We reaffirm that approach here. Qualitatively, a factfinder may look to whether the fund was a “popular option[ ] offered by other employers’ plans of comparable size and complexity” and whether it “received p…
12. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
13. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998
    …se to an employer or trustee's request for a determination. * * * [S. Rept. 93-383 (accompanying S. 1179), at 116 (1973), 1974-3 C.B. (Supp.) 80, 195.] The bill was altered in conference, so that instead of a 90-day filing period, section 7476(b)(5) requires that a petition be filed "before the ninety-first day after t…
14. T.C. Memo. 2016-15 — Robert Leon Martin v. Commissioner
    IRCCourt RulingsFeb 3, 2016
    …chine and lottery winnings, are includible in gross income. See United States v. Maginnis, 356 F.3d 1179, 1183 (9th Cir. 2004) (lottery winnings); Park v. Commissioner, - 7 - [*7] 136 T.C. 569, 573 (2011) (slot machine winnings), rev'd and remanded on other grounds, 722 F.3d 384 (D.C. Cir. 2013). There may be some ques…
15. 62 T.C. 166; 14 U.C.C. Rep. Serv. (West) 1165 — Don E. Williams Co. v. Commissioner
    IRCCourt RulingsMay 14, 1974
    …hibited by the terms of the Senate bill. The Report of the Senate Finance Committee accompanying S. 1179 contains the following:
16. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
17. T.C. Memo. 2009-218 — Von H. Argyle v. Commissioner
    IRCCourt RulingsSep 17, 2009
    …64, sec . 5 .03 , 2004-2 C .B . 898 , 900 ; Rev . Proc . 200578, sec . 5 .03 , 2005-2 C .B . 1177 , 1179 ; see also , e .g ., Nash v . Commissioner , 60 T .C . 503, 520 (1973) ; Clark v . Commissioner , T .C . Memo . 2002-32 . He claims that he is entitled to use section 280A ( d)(4)(A) to deduct all of the expenses co…
18. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
19. 69 T.C. 750 — Orzechowski v. Commissioner
    IRCCourt RulingsFeb 22, 1978
    …le to the contributor, and he could not establish another qualified IRA for a period of 5 years. S. 1179, 93d Cong., 1st Sess., sec. 701(b), 119 Cong. Rec. 28467 (1973); S. Rept. 93-383 at 212.
20. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014
    …e plain meaning of the statute), rev'g 102 T.C. 61 (1994); Matthews v. Commissioner, 907 F.2d 1173, 1179 (D.C. Cir. 1990) (holding that the language of the statute is "too plain to be mistaken"), aff'g 92 T.C. 351 (1989). And the Supreme Court has reminded us. Badaracco v. Commissioner, 464 U.S. 386, 398 (1984) (affirm…