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1. T.C. Memo. 2013-126 — Laura Ung v. Commissioner
   IRCCourt RulingsMay 13, 2013
   …cedes that she received a taxable distribution from her Fidelity Investments retirement account of $256 that was unreported for 2008. Finally, petitioner concedes that she received a $20,000 taxable distribution from her Morgan Stanley retirement account that was originally unreported on her 2008 tax return. - 3 - [*3]…
2. 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…
3. 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was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
4. T.C. Memo. 2006-95 — Theodus J. Jordan v. Commissioner
   IRCCourt RulingsMay 8, 2006
   …1,725 of the $1,738 offset amount, along with $531 of Federal income tax withheld, in claiming a $2,256 overpayment. In the notice of deficiency, respondent increased petitioner’s deficiency by $2,256, with an explanation that this adjustment reflected the disallowance of an additional child tax credit. The parties hav…
5. REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv…
   IRCProposed Rules (FR)Proposed May 28, 2013
   …x 5%)) on December 31, 2017; $33,101 ($21,525 + $10,000 + ($31,525 x 5%)) on December 31, 2018; $45,256 ($33,101 + $10,000 + ($43,101 x 5%)) on December 31, 2019; and $58,019 ($45,256 + $10,000 + ($55,256 x 5%)) on December 31, 2020.
6. PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
   IRCPrivate Letter RulingsSep 25, 2009
   …s basic function the systematic liquidation of the principal.” Se e also Comm’r v. Meyer , 139 F.2d 256 (6th Cir. 1943). Similarly, in Rev. Rul. 75-255, 1975-2 C.B. 22, the Service observed
7. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
   IRCCourt RulingsJun 17, 1997
   …nefits and DWB's as shown below: 1989 1990 1991 1992 1993 1994 Total DWB's (number) 0 6 50 57 87 56 256 Withdrawal dist. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4…
8. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
   ERISAProposed Rules (FR)Proposed Jul 27, 2022
   …ted parties. If both applications result in a published proposed exemption each year, approximately 256 notices to interested parties will be distributed to the QPAMs' client Plans, and, if the proposed exemption is granted, an objective description also must be distributed to interested parties that describes the fact…
9. 74 T.C. 651 — Judd v. Commissioner
   IRCCourt RulingsJul 8, 1980related by meaning
   2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
10. 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…
11. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …rt higher premiums (29 percent compared to 41 percent) than those utilizing the three largest PBMs.[256]
12. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …010, the day petitioners made their withdrawal, the cash value of the ING annuity contract was $761,256. Petitioners thus had $186,302 of "income on the contract" (cash value of $761,256 minus their "investment in the contract" of $574,954). Because the amount of the withdrawal, or $525,000, ex5When Allstate passed the…
13. 80 FR 2010 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Jan 15, 2015
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 256 is added to 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 annuities (perc…
14. 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…
15. Treas. Reg. § 54.4975-7(b)(8)(iv) — Other statutory exemptions.
    IRCRegulationsDec 30, 2016
    …antees the loan, which is for 15 years at 5% interest and is payable in level annual amounts of $72,256.72. Total payments on the loan are $1,083,850.80. The ESOP uses the entire loan proceeds to acquire 15,000 shares of X stock which is used as collateral for the loan. The number of securities to be released for the f…
16. 29 C.F.R. § 2550.408b-3(h)(4) — Loans to Employee Stock Ownership Plans.
    ERISARegulationsJan 1, 2017
    …rantees the loan which is for 15 years at 5% interest and is payable in level annual amounts of $72,256.72. Total payments on the loan are $1,083,850.80. The ESOP uses the entire proceeds of the loan to acquire 15,000 shares of X stock which is used as collateral for the loan. The number of securities to be released fo…
17. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
18. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    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…
19. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
20. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    e conditions named in section 6404(e)(1) are met. The word "may" - 18 - [*18] signifies that Congress has conferred discretion on the Secretary of the Treasury. C[ Porter v. Commissioner, 132 T.C. 203, 206-208 (2009), abrogating Butler v. Commissioner, 114 T.C. 276 (2000); see also id. at 237-238 (Gustafson, J., dissen…