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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
2. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
   IRCCourt RulingsMar 5, 2018related by meaning
   Roth IRAs Were Exposed to No Risk.. . . . . . . . . . . . . . . . . 43 B. The Roth IRAs Could Expect No Upside Benefits . . . . . . . . . . . 47 -4 - C. Conclusion .......................................... 49 VII. Petitioners' Counterarguments .............................. 51 A. Summa Holdings II ...................…
3. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
   IRCCourt RulingsApr 20, 2017related by meaning
   402(c)(3)(B). See SERVED Apr 20 2017 - 2 - Rev. Proc. 2003-16, 2003-1 C.B. 359, as modified retrospectively by Rev. Proc. 2016-47, 2016-37 I.R.B. 346. Ideld, further, the Tax Court has jurisdiction in this deficiency proceeding to review R's denial of Ps' request for a waiver of the 60day rollover requirement. Held, fu…
4. 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…
5. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
   IRCCourt RulingsMay 27, 1968related by meaning
   404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
6. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
   IRCCourt RulingsJul 13, 1995related by meaning
   OPINION Wright, Judge: Respondent determined a deficiency in petitioner’s Federal income tax for taxable year 1990 in the amount of $239,463. After concessions by the parties, the issues for our consideration are as follows: (1) Whether dividends paid to an employee stock ownership plan, deductible under section 404(k)…
7. 56 T.C. 263 — Smith v. Comm'r
   IRCCourt RulingsMay 12, 1971related by meaning
   g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
8. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
   IRCCourt RulingsSep 19, 1978related by meaning
   Tannenwald, Judge: Respondent determined the following deficiencies in petitioner’s Federal income tax: Docket No. TYE— Deficiency 10703-75 ..Oct. 31; 1970 $6,517.00 Oct.. 31, 1971 7,547.00 903-77 .Oct. 31, 1972 2,108.74 Sept. 30, 1973 2,067.29 The sole issue remaining for decision is whether petitioner is barred from …
9. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
   IRCCourt RulingsJan 12, 1998related by meaning
   ontrol of the use of the IRA distributions. We are not persuaded by respondent's argument that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the forfeiture, and his avoidance of a fine or potentially longer prison sentence, petitioner should be treated …
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. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
12. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    .a distribution of $6,277 from a qualified retirement . plan during~the'2001 tax year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that she qualified for any of the . exceptions in section 72(t)(2) . Accordingly ; we hold that Ms .-O'Boyle…
13. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
14. 49 T.C. 174 — Armanco Productions, Inc. v. Commissioner
    IRCCourt RulingsDec 8, 1967related by meaning
    dic or annual compensation on the basis of permanent employment; (c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…
15. 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…
16. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
17. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    .R.C. sec. 6662(a) penalties as redetermined in this opinion. Matthew Taggart, Ryan Andrews, Michael B. Luftman, and Charles Kolstad, for petitioners. Kris H. An, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: These cases are before the Court on petitions for redetermination of income tax and ex…
18. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
19. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
20. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…