ERISACourt RulingsSep 29, 2026
…e don’t resolve
inference s in favor of either party. Ian C. v. UnitedHealthcare Ins. Co.,
87 F.4th 1207, 1217 (10th Cir. 2023).
Appellate Case: 25-3160 Document: 60-1 Date Filed: 09/29/2026 Page: 6
7
Such discretion exists here;
3
so we must uphold the plan
administrator’s interpretation unless it is arbitrary and cap…
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…
IRCCourt RulingsMar 9, 2011
…porate entity for tax purposes if it were not a DISC. Addison Intl.,
Inc. v. Commissioner,. 90 T.C. 1207 (1988), affd. 887 F.2d 660
(6th Cir. 1989); Jet Research, Inc. v.+ Commiessioner,- T.C. Memo.
1990-463; see also sec. 1.992-1(a)s, Income Tax Regs. ".The DISC
may be no more than a shell corporation, which performs …
IRCCourt RulingsFeb 9, 2023
…d Appropriations Act, 2018, Pub. L. No. 115-141, div. U, sec. 401(d)(1)(D)(viii)(III), 132 Stat. at 1207. Section 367(d)(4)
provides:
220
For purposes of this subsection, the term “intang ible
property” means any --
(A) patent, invention, formula, process,
design, pattern, or know-how,
(B) copyright, literary, musical,…
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
…er year. HHS will amend the information collection currently approved under OMB control number 0938-1207 (Medicaid and Children's Health Insurance Programs: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes, and Premiums and Cost Sharing; Exchanges: Eligibili…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCCourt RulingsMar 5, 2018★ strong match
…I, 848 F.3d at 782; Addison
Int'l, Inc. v. Commissioner, 887 F.2d 660, 666 (6th Cir. 1989), 90 T.C. 1207
(1988); Hellweg v. Commissioner, T.C. Memo. 2011-58, 2011 WL 821090, at *5.
FSCs were very similar--barely-there entities through which businesses could
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
IRCCourt RulingsMay 22, 2025
…solidated
Appropriations Act, 2018, Pub. L. No. 115- 141, § 401(d)(1)(D)(viii)(III), 132 Stat. 348,
1207. The definition in section 367(d)(4) differs in style but not substance from the
2017 definition in section 936(h)(3)(B).
120
IRCCourt RulingsOct 10, 2018
…resentation to the drawee (i.e.,
the bank in this case). Estate of Hubbell v. Commissioner, 10 T.C. 1207, 1208
(1948) (citing Eagleton v. Commissioner, 35 B.T.A. 551 (1937), af[d, 97 F.2d 62
(8th Cir. 1938)); see also, e.g., Muldrow v. Tex. Frozen Foods, Inc., 299 S.W.2d
275, 277-278 (Tex. 1957) ("[I]t is well settled …
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsAug 27, 2008
…ency ." Cupp v . Commissioner , 65 T .C . 68, 83 (1975), affd . without published opinion 559 F .2d 1207 (3d Cir .
1977) . More generally and with respect to petitioner's second
argument, the Court will not look behind a notice of deficiency
to question the Commissioner's procedures leading to the
determination of a de…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsJan 2, 2025
…trive a fictional debt” (quoting United States v. Uneco, Inc. ( In re Uneco, Inc. ), 532 F.2d 1204, 1207 (8th Cir. 1976))), aff’d , 521 F. App’x 476 (6th Cir.
2013).
25
[* 25] any credible documents in the record. For example, they claim
that an independent actuary firm valued NRSP Management at
$75 million in 2009. Th…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsJun 14, 1982
…tioners in this Court.
We quote from Cupp v. Commissioner, 65 T.C. 68, 85-86 (1975), affd. 559 F.2d 1207 (3d Cir. 1977):
IRCCourt RulingsFeb 9, 1998
…alid return. Cupp v.
Commissioner
, 65 T.C. 68, 78 (1975), affd. without published
opinion 559 F.2d 1207 (3d Cir. 1977); Kelly v. Commissioner
, T.C.
Memo. 1987-352, affd. without published opinion 858 F.2d 743
(11th Cir. 1988). Petitioner's failure to file a valid tax
return for 1989 was not due to reasonable cause. R…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
IRCCourt RulingsJul 30, 2012
… capital is not considered a
debt. United States v. Uneco, Inc. (In re Uneco, Inc.), 532 F.2d 1204, 1207 (8th
Cir. 1976); sec. 1.166-1(c), Income Tax Regs. To determine whether a bona fide
debt exists, we consider objective and subjective factors. In re Uneco, Inc., 532
F.2d at 1209.
Petitioner's transfers from his IRA…