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1. 69 T.C. 1055; 1 Employee Benefits Cas. (BNA) 1610 — Kiddie v. Commissioner
   IRCCourt RulingsMar 30, 1978
   Sterrett, Judge: Respondent, on April 30, 1976, issued a statutory notice of deficiency in which he determined the following deficiencies in petitioner’s Federal corporate income taxes: Taxable year Deficiency 1971 .... ..$7,962.31 1972 .... ..16,972.52 1973 .... ...4,613.50 Due to concessions made by the parties the s…
2. 39 T.C. 1055 — Cohen v. Commissioner
   IRCCourt RulingsMar 27, 1963
   Withe y, Judge: Respondent has determined a deficiency in the income tax of petitioners for the year 1958 in the amount of $23,100.99. Petitioner claims an overpayment in his income tax for 1958. The issues presented for our decision are (1) whether gain realized by petitioner Theodore H. Cohen upon the transfer of cer…
3. ERISA § 206(d)(4)(B) (29 U.S.C. § 1056) — Form and payment of benefits
   ERISACode / StatuteJan 6, 2025
   …d under the plan, and (d)(4)(C) (C) in a case in which the survivor annuity requirements of section 1055 of this title apply with respect to distributions from the plan to the participant, if the participant has a spouse at the time at which the offset is to be made— (d)(4)(C)(i) (i) either— (d)(4)(C)(i)(I) (I) such sp…
4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
5. 73 T.C. 5; 1 Employee Benefits Cas. (BNA) 1614 — Garland v. Commissioner
   IRCCourt RulingsOct 4, 1979
   …ship employees under the principles set forth in Thomas Kiddie, M.D., Inc. v. Commissioner, 69 T.C. 1055, 1060-1061 (1978).
6. ERISA § 203(a)(2)(B) (29 U.S.C. § 1053) — Minimum vesting standards
   ERISACode / StatuteJan 6, 2025
   … participant dies (except in the case of a survivor annuity which is payable as provided in section 1055 of this title).
7. 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…
8. 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…
9. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
   IRCCourt RulingsJun 26, 2017related by meaning
   e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…
10. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
11. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
12. ERISA § 204(c)(2)(B) (29 U.S.C. § 1054) — Benefit accrual requirements
    ERISACode / StatuteJan 6, 2025
    …g at normal retirement age, using an interest rate which would be used under the plan under section 1055(g)(3) of this title (as of the determination date). (c)(2)(C) (C) For purposes of this subsection, the term "accumulated contributions" means the total of— For purposes of this subparagraph, the term "mandatory cont…
13. 41 T.C. 685 — Conroy v. Commissioner
    IRCCourt RulingsFeb 26, 1964related by meaning
    It follows, therefore, that the amounts received by petitioners from the special fund are not excludable from gross income under either section 104 or section 105 unless they are covered by subsection 105(b), subsection 105(c), or subsection 105(d). Only the last subsection (105(d)), to which petitioners make no refere…
14. 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…
15. ERISA § 113(b)(1)(C)(ii) (29 U.S.C. § 1032) — Notice and disclosure requirements with respect to lump sums
    ERISACode / StatuteJan 6, 2025
    (b)(1)(C)(ii) (ii) the qualified joint and survivor annuity (as defined in section 1055(d)(1) of this title); (b)(1)(D) (D) A statement that— (b)(1)(D)(i) (i) a commercial annuity comparable to the annuity available from the plan may cost more than the amount of the lump sum amount, and (b)(1)(D)(ii) (ii) it may be adv…
16. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…
17. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …rk, Inc. v. Commissioner , 98 T.C. 511, 514-515 (1992); Paula Constr. Co. v. Commissioner , 58 T.C. 1055, 1058-1059 (1972),
18. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
19. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    …vg. and remanding on another issue T.C. Memo. 1980-282; Paula Constr. Co. v. Commissioner , 58 T.C. 1055, 1058 (1972), affd. without published
20. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    d the correctness of respondent’s interpretation of the interplay of sections 72,104, and 105 and the regulations thereunder as applied to their case. What petitioners do challenge, however, is the constitutionality of sections 104(a)(4) and 105(d) in an effort to bring their disability payments within the exclusions f…