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1. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
   IRCCourt RulingsAug 12, 1998
   T.C. Memo. 1998-295 UNITED STATES TAX COURT SHEDCO, INC., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17268-95R. Filed August 12. 1998. John F. Daniels III and Neil H. Hiller , for petitioner. Ann W. Durning and J. Robert Cuatto , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARR, …
2. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
   IRCFinal Rules (FR)May 6, 2024related by meaning
   portion of the section 30D credit to which section 30D(c)(1) applies. The IRA did not amend section 30D(c)(1) or (2). B. IRA Amendments to Section 30D 1. Credit Amount and Critical Minerals and Battery Components Requirements
3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
   IRCCourt RulingsJan 14, 2013★ strong match
   Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
5. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
   IRCCourt RulingsSep 25, 1996
   …he agreement recited that MIT 80 agreed to accept the 500 shares from MPC in full payment of the $1,295,108 due to it from MPC. None of the parties to this transaction were represented by counsel. No one made a formal appraisal of the MIT Transportation Co. stock. Bruce nevertheless issued a memorandum to the MIT 80 pa…
6. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
   IRCCourt RulingsJul 15, 1997related by meaning
   3,200. 5,000 furniture and The corporation conceded fixtures entire amount to be not deductible; respondent allowed - 21 - additional ACRS deductions pursuant to section 168. Taxable Year Ending December 31, 1987 Amount of Purpose of deduction claimed deduction claimed by the corporation by the corporation Concessions…
7. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
   IRCCourt RulingsAug 17, 2026
   …qualification s and the evidence in the record. Se e Helvering v. Nat’l Grocery Co. , 304 U.S. 282, 295 (1938); Estate of Mellinger v. Commissioner, 112 T.C. 26, 39 (1999). The persuasiveness of an expert’s opinion depends largely on the facts and assumptions on which it is based . Estate of Davis v. Commissioner, 110 …
8. 83 FR 15946 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
   PBGCFinal Rules (FR)Apr 13, 2018
   …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 295 is added at the end of the table to read as follows: Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annu…
9. 88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act
   IRCProposed Rules (FR)Proposed Feb 2, 2023
   …50 percent of the burden, or approximately 5,267 hours annually, with an equivalent annual cost of $295,039. DOL and the Department of the Treasury would each account for 25 percent of the burden, as discussed in section VI.E of this preamble. Table 6—Annual Burden and Costs for Individuals Estimated number of responde…
10. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ccord Grajales, 156 T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68, Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional amount” within the meaning of section 6751(c). To implement the foregoing, An order will be issued g…
11. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    … (In-House) 70,322 = 703,224 Small Plans × 10% Not Using a Service Provider 4 181.06 281,290 50,930,295 Total 295,498 53,502,795 Table 19—Cost for Preparation of 2002 Safe Harbor Notice Description Affected entities Hours per entity Hourly labor cost Total hours Equivalent cost   (A) (B) (C) (A × B) (A × B × C) Notice …
12. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007related by meaning
    iable for the $1,990 10-percent additional tax on the $19,900 early IRA distribution Mary received. To reflect the foregoing, Decision will be entered under Rule 155 .
13. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …ble. Ranch Springs, 164 T.C. at 128 ( first citing Helvering v. Nat ’ l Grocery Co. , 304 U.S. 282, 295 (1938) ; and then citing Boltar, L.L.C. v. Commissioner, 136 T.C. 326, 333– 40 (2011) ); Parker, 86 T.C. at 561. We
14. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
15. 29 C.F.R. § 4044.30 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
16. 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 …
17. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …e (as in effect prior to amendments made by the Tax Increase Prevention Act of 2014, Public Law 113-295, 128 Stat. 4010) and paragraph (h)(4) of this section.
18. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990
    … 14,045 2,528 281 Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $295,956. Robert H. McCollough Docket No. 39550-87 Sec. 4975(a) first-tier tax Additions to tax TYE deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) 12/31/80 $1,170 $263 $293 12/31/81 12/31/82 3,305 5,154 744 1,160 826 1,031 12…
19. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
20. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … to 64 with diabetes, hypertension, or heart disease based on adherence status (see Table 5 below).[295] Observing the average number of distinct medical events, such as inpatient hospitalizations or office-based visits to physicians, the data suggests that across most categories of healthcare, cost-related non-adheren…