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1. 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.
2. 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…
3. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
   ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
   able solely to the proposed new covered transaction. The proposed new Section IV incorporates conditions currently applicable to PTE 75-1, Part II(2). Specifically, the conditions applicable to the proposed new covered transaction in Section I(b), as set forth in proposed Section IV, are: (1) The fiduciary customarily …
4. 66 T.C. 324 — Bianchi v. Commissioner
   IRCCourt RulingsMay 20, 1976related by meaning
   ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
5. 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
6. 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 …
7. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
   IRCTreasury DecisionsAug 28, 2006related by meaning
   n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
8. 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 …
9. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
   IRCCourt RulingsJun 25, 2013related by meaning
   rty from an individual to * * * a former spouse, but only if the transfer is incident to the divorce." This Court has generally held that transfers of property between spouses incident to a divorce "neither are taxable events nor give rise to deductions or recognizable income." Estate of Goldman v. Commissioner, 112 T.…
10. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    item of income that is received in cash or in the form of a “cash equivalent.” Secs. 1.61-2(d), 1.446-1(a)(3), and 1.446-1(c)(1)(i), Income Tax Regs. On February 3, 1978, respondent published in the Federal Register Proposed Income. Tax Regs, section 1.61:16 relating to the tax treatment of ainounts of compensatory pa…
11. 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…
12. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
13. 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…
14. Treas. Reg. § 1.410(b)-1 — [Reserved]
    IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
15. 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 …
16. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    ents was this estimate, to which respondent reserved an objection on grounds of relevance and authenticity. We overrule respondent's objection. - 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets to the extent of the gain from such sales or exchanges, plus the lower of: (1) $3,000 o…
17. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
18. 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).
19. 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…
20. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…