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80 documents · 0.73sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …5 13,000 $12,923 1986 15,521 18,764 1987 26,769 29,077 1988 36,000 36,000 1989 36,000 36,000 1990 4,154 4,154
  2. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    IRCCourt RulingsMar 3, 2016
    … to the IRS, the income was not included on the income tax return: a Form 1099-R reporting the $109,154 IRA distribution from RBS Citizens Bank; a Form 1099-INT, Interest Income, reporting interest income of $13 from EMC Mortgage Corp.; a Form 1099-DIV, Dividends and Distributions, reporting taxable dividend income of …
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  5. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …atements Pre-Statute 96.1 3.9 0.0 $0 $0 $0 $0 $0 1 51.3 48.7 44.8 53,502,795 18,284,236 4,949,140 5,154,737 81,890,909 2 57.3 42.7 38.8 0 0 0 4,471,532 4,471,532 3 60.2 39.8 35.9 0 0 0 4,139,119 4,139,119 4 61.7 38.3 34.4 0 0 0 3,977,383 3,977,383 5 62.3 37.7 33.8 0 0 0 3,898,691 3,898,691 6 62.7 37.3 33.4 0 0 0 3,860,…
  6. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  7. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    g "abuse of tax favored treatment” is to preclude implementation of plans that threaten to increase the cost of the pension system in unintended ways. It is not apparent that Congress intended that actuaries include assumptions as to future cost-of-living adjustments when calculating a current year’s contributions or t…
  8. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … additional performance metrics for private funds—such as: (1) the public market equivalent (PME); [154] (2) the modified IRR (MIRR) which adjusts for timing of investment flows; (3) the multiple on invested capital (MOIC) which measures the total value returned to investor relative to the total capital invested; [155]…
  9. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171 (1931)), aKg T.C. Memo. 1982-209. With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed below, we reject petitioners' broadest argument--that the substance doctrines have no…
  10. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ir health-care budgets, with the median share rising from 21 percent in 2021 to 27 percent in 2023.[154]
  11. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    .B. 27 ; Rev. Rul. 67-213, 1967-2 C.B. 149; Rev. Rul. 68-160, 1968-1 C.B. 167 ; Rev. Rul. 69-254, 1969-1 C.B. 129 ; Rev. Rul. 71-541, 1971-2 C.B. 209. This Court has previously noted that an error committed by a third party contrary to the express desires of a taxpayer should not necessarily control the tax effects of …
  12. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    … PROCEDURE? 152 .01 In general 152 .02 Specific changes 153 PART I. GENERALLY APPLICABLE PROCEDURES 154 >SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 154 .01 In general 154 .02 Letter ruling 154 .03 Closing agreement 154 .04 Determination letter 154 .05 Opinion letter 155 .06 Ora…
  13. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
  14. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    Rev. Proc. 2020–4 TABLE OF CONTENTS SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 154 .01 Purpose of revenue procedure 154 .02 Organization of revenue procedure 154 .03 Other guidance affecting this revenue procedure 154 .04 Updated annually 157 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 20…
  15. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962related by meaning
    ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated. Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act. Thls section was originally desi…
  16. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …l years previously. Between 2003 and 2006 petitioners made additional after-tax investments of $346,154 in the Allstate annuity contract. In March 2007 petitioners surrendered the Allstate annuity and transferred the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of the Al…
  17. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    … revenue procedure 152 .03 Other guidance affecting this revenue procedure 152 .04 Updated annually 154 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4? 154 .01 In general 154 .02 Changes made to Revenue Procedure 2018–4 154 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PR…
  18. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  19. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  20. 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…