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64 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …r, 143 T.C. at 382 ( q uoting Spurlock v. Commissioner, T.C. Memo. 2003- 124, 85 T.C.M. (CCH) 1236, 1244).
  2. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …4, 719 – 20 (1982), aff’d , 731 F.2d 1417 (9th Cir. 1984); Markosian v. Commissioner, 73 T.C. 1235, 1244 – 45 (1980); Saccato v. Commissioner, T.C. Memo. 2023-96, at *8. Whether a trust
  3. 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…
  4. Treas. Reg. § 1.414(c)-4(b)(5)(ii)(D) — Rules for determining ownership.
    IRCRegulationsSep 9, 2016
    …ividends”, and “annuities” shall have the same meaning such terms are given for purposes of section 1244(c) and § 1.1244(c)-1(e)(1). (b)(6) (6) Children, grandchildren, parents, and grandparents
  5. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  6. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    ense that it caused.to surface a meritorious section 72(t) issue and resulted in respondent's I "Respondent's concession is presumably based upon sec. 72(t) (2) (A) (iv), which provides that the 10-percent additional tax does not apply to distributions which are "part of a series of substantially equal periodic payment…
  7. Treas. Reg. § 1.1563-3(b)(5)(ii)(D) — Rules for determining stock ownership.
    IRCRegulationsDec 30, 2024
    …nterest”, and “annuities” shall have the same meanings such terms are given for purposes of section 1244(c). See paragraph (e)(1)(ii), (iii), (iv), (v), and (vi) of § 1.1244(c)-1. (b)(6) (6) Children, grandchildren, parents, and grandparents.
  8. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  9. 29 C.F.R. § 2570.7 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
  10. 29 C.F.R. § 2570.63 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  11. 29 C.F.R. § 2570.113 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  12. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    … a taxpayer's statement of intent. Simon v. Commissioner , supra ; Thomas v. Commissioner , 84 T.C. 1244, 1269 (1985), affd. 792 F.2d 1256 (4th Cir. 1986); sec. 1.183-2(a), Income Tax Regs. The promoters and partners knew enough to stress at trial their personal hopes of great profits. Thus, while Fred urged them to "t…
  13. 29 C.F.R. § 2570.3 — Service: Copies of documents and pleadings.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.3 of this title.
  14. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962
    …a term or for an amount certain despite the annuitant’s death; see, e.g., Elliott C. Morse, 17 T.C. 1244, affd. 202 F. 2d 69 (C.A. 2, 1953); Renton K. Brodie, 1. T.C. 275; but the distinction goes only to value or the amount to be included in income and not forfeitability.
  15. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  16. 85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
    IRCFinal Rules (FR)Nov 6, 2020
    …k to Citation 74.  Using data from the BLS for Network and Computer Systems Administrators (Code 15-1244), we estimate that the average hourly labor cost will be $85.02, including 100 percent increase for overhead and fringe benefits. https://www.bls.gov/​oes/​current/​oes_​stru.htm. Back to Citation 75.  Boynton, A., …
  17. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  18. 82 T.C. 686; 82 T.C. No. 53 — Holswade v. Commissioner
    IRCCourt RulingsApr 26, 1984
    …ble. Coughlin v. Commissioner, 203 F.2d 307 (2d Cir. 1953); Coffey v. Commissioner, 21 B.T.A. 1242, 1244 (1931). When, as in the instant case, the trip combines both business and personal activities, then the entity claiming the deduction (in the instant case, the corporation) must prove that the trip was primarily rel…
  19. 29 C.F.R. § 2570.133 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  20. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…