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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   ….S. 29 (1983); Altera Corp. & Subs. v. Commissioner , 145 T.C. 91, 120, 130 (2015), rev’d, 926 F.3d 1061 ( 9th 2019). P also contends that the entire regulation addressing foreign legal restrictions , 26 C.F.R. sec. 1.482-1(h)(2) (2006) , is invalid unde r the part of 3 the State Farm test that requires the agency to g…
2. ERISA § 211(a) (29 U.S.C. § 1061) — Effective dates
   ERISACode / StatuteJan 6, 2017
   (a) (a) Except as otherwise provided in this section, this part shall apply in the case of plan years beginning after September 2, 1974.
3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
   IRCCourt RulingsFeb 28, 2024related by meaning
   years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
4. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsMay 22, 2025
   … prevent tax evasion by related business taxpayers.” Altera Corp. & Subs. v. Commissioner, 926 F.3d 1061, 1068 (9th Cir. 2019), rev’g 145 T.C. 91 (2015). 118 The second sentence of section 482 was enacted in 1986. Tax
5. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
   IRCCourt RulingsNov 14, 1996
   … 674. vest , during the year or within 2-1/2 months after the end of the year. [H. Rept. 100-391 at 1061-1062 (1987); S. Print 100-63 at 143-144 (1987); emphasis added. 11 ] Respondent argues that a proper reading of the foregoing language indicates that the committees intended to draw a distinction between situations …
6. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
   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…
7. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
   IRCCourt RulingsAug 12, 1998
   …literally. Time Oil Co. v. Commissioner , 258 F.2d 237 (9th Cir. 1958), revg. and remanding 26 T.C. 1061 (1956); Bing Management Co. v. Commissioner , T.C. Memo. 1977-403. To that effect, the Commissioner has indicated that the exclusive benefit test of section 401(a)(2) does not prohibit others from benefiting from a …
8. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
   IRCCourt RulingsJul 5, 1983related by meaning
   so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
9. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
   IRCCourt RulingsNov 5, 1999
   …057 (1970); Time Oil Co. v. Commissioner , 258 F.2d 237, 238-239 (9th Cir. 1958), remanding 26 T.C. 1061 (1956). If a violation of the exclusive benefit rule is found, then we look to the totality of the transgressions that occurred in assessing whether it is an abuse of discretion for the Commissioner to disqualify th…
10. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
11. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    …999) (document filed postassessment not a valid return under Beard ); In re Hatton , 220 F.3d 1057, 1061 (9th Cir. 2000) (“belated acceptance of responsibility * * * does not constitute an honest and reasonable attempt to comply with the requirements of the tax law” when taxpayer filed a document purporting to be a ret…
12. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
13. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
14. 67 T.C. 167 — Quality Brands, Inc. v. Commissioner
    IRCCourt RulingsNov 8, 1976
    …judging the qualification of the plan, and they reinforce our conclusion. See Time Oil Co., 26 T.C. 1061 (1956), remanded on another issue 258 F.2d 237 (9th Cir. 1958); Myron v. United States, 382 F.Supp. 590 (C.D. Cal. 1974).
15. 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…
16. 73 T.C. 5; 1 Employee Benefits Cas. (BNA) 1614 — Garland v. Commissioner
    IRCCourt RulingsOct 4, 1979
    …ees under the principles set forth in Thomas Kiddie, M.D., Inc. v. Commissioner, 69 T.C. 1055, 1060-1061 (1978).
17. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
18. 68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner
    IRCCourt RulingsSep 12, 1977
    … Petitioner also cites Time Oil Co. v. Commissioner, 258 F.2d 237 (9th Cir. 1958), remanded 26 T.C. 1061 (1956), for the proposition that operational variances can be deemed too "slight” to disqualify the plan, based on whether those variances prejudiced the benefits to be received by the beneficiaries and improved the…
19. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
20. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980
    …ent, petitioner cites Time Oil Co. v. Commissioner, 258 F.2d 237 (9th Cir. 1958), remanding 26 T.C. 1061 (1956), and Community Services, Inc. v. United States, 191 Ct. Cl. 76, 422 F.2d 1353 (1970).