Search the Pension Law Library

1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   t to which the restrictions apply) has exhausted all remedies prescribed by foreign law or practice for obtaining a waiver of such restrictions (other than remedies that would have a negligible prospect of success if pursued); (C) The restrictions expressly prevented the payment or receipt, i n any form, of part or all…
2. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
   IRCNoticesJun 8, 2026
   term rate is set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570. Section 467.—Certain Payments for the Use of Property or Services The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570. Section 468.—Special Rules f…
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. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
   IRCCourt RulingsApr 2, 2024related by meaning
   , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
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. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
   IRCCourt RulingsFeb 22, 1989related by meaning
   n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
7. 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…
8. 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.
9. 29 C.F.R. § 4907.171-4907.999 — [Reserved]
   PBGCRegulationsJan 1, 2017related by meaning
   [Reserved]
10. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
11. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    …orization Act for Fiscal Year 1991 (NDAA), Pub. L. 101-510, sec. 555(b)(3), (e)(2), 104 Stat. 1569, 1570 (1990). - 7 - Under California law post- McCarty , military retirement benefits earned during marriage are community property. Casas v. Thompson , 720 P.2d 921, 925 (Cal. 1986); see Gillmore v. Gillmore , 629 P.2d 1…
12. 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.
13. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001
    …efense Authorization Act for Fiscal Year 1991, Pub. L. 101-510, sec. 555(b), (e)(2), 101 Stat. 1569-1570. The Supreme Court in McCarty v. McCarty , 453 U.S. 210 (1981), held that Federal statutes governing military retirement pay prevented State courts from treating military retirement pay as community property. In dir…
14. 29 C.F.R. § 4907.161-4907.169 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
15. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989
    …ing with the section 6033 filing requirement. Cf. Consolidated Apparel Co. v. Commissioner, 17 T.C. 1570, 1583 (1952), affd. in part and revd. in part on another issue 207 F.2d 580 (7th Cir. 1953) (return substantially complied with statutory requirement that it be signed by a “principal officer” and a financial office…
16. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
17. 29 C.F.R. § 2570.166 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
18. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    ed CST, an entity owned by his IRA, to enter into a lease agreement with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for the year in which the prohibited transaction occurred petitioners are liable for the additio…
19. 29 C.F.R. § 2570.136 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
20. 29 C.F.R. § 2570.161 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title: