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70 documents · 0.54sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …These are quintessential “significant comments.” See, e.g ., La. Fed. Land Bank Ass’n , 336 F.3d at 1080; Balt. Gas & Elec. Co ., 817 F.2d Cir. 1991) ; Hussion v. Madigan , 950 F.2d 1546, 1554 (11th Cir. 1992) ; Huawei Techs. USA, Inc. v. FCC , 2 F.4th 421, 449 (5th Cir. 2021) . 323 at 116. Treasury was required to res…
  2. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ternational Journal of the Economics of Business, (2015) https://www.tandfonline.com/​doi/​full/​10.1080/​13571516.2015.1045741. Back to Citation 167.  Frier Levitt, Pharmacy Benefit Manager Expose: How PBMs Adversely Impact Cancer Care While Profiting at the Expense of Patients, Providers, and Employers, and Taxpayers…
  3. 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…
  4. 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…
  5. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    must decide whether the Court has jurisdiction to review respondent's whistleblower claim award determination where the claim is based on information the whistleblower provided both before and after the enactment of TRHCA sec. 406, 120 Stat. at 2958.9 ¹° I. Overview of the Court's Jurisdiction and the Whistleblower Pr…
  6. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  7. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  8. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    n fund. Accordingly, because petitioner constructively received the IRA distribuitions in 2009, they are includable in his gross income for that year. Petitioner lastly argues that the 2008 garnishment order violated the Consumer C edit Protection Act as well as the Mandatory Victims Restitution Act. Petitioner request…
  9. 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…
  10. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    125 T.C. No. 5 UNITED STATES TAX COURT SERVICE EMPLOYEES INTERNATIONAL UNION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent 100 OAK STREET CORPbRATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 . saan. Ps are qualified labor. organi…
  11. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
  12. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  13. 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…
  14. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004
    … an election. See Bond v. Commissioner , 100 T.C. 32 (1993); Taylor v. Commissioner , 67 T.C. 1071, 1080 (1977); Hewlett- Packard Co. v. Commissioner , 67 T.C. 736, 748 (1977); Columbia Iron & Metal Co. v. Commissioner , 61 T.C. 5 (1973); Sperapani v. Commissioner , 42 T.C. 308 (1964); Cary v. Commissioner , 41 T.C. 21…
  15. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  16. T.C. Summary Opinion 2006-170 — Nader Ghazitehrani and Farzaneh Zamanizadeh v. Commissioner
    IRCCourt RulingsOct 23, 2006related by meaning
    T .C . Summary Opinion 2006-17 0 UNITED STATES TAX COUR T NADER GHAZITEHRANI AND FARZANEH ZAMANIZADEH, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 12653-05S . Filed October 23, 2006 . Nader Ghazitehrani and Farzaneh Zamanizadeh, pro sese . Aimee R . Lobo-Berg , Thomas J . Travers , and Ann…
  17. PLR 201313025 — Taxability of Beneficiary of Employee's Trust (Time and Manner of Taxation)
    IRCPrivate Letter RulingsMar 29, 2013
    …ithout published opinion , 212 F.3d 600 (11th Cir. 2000). See also Janis v. Commissioner , 461 F.3d 1080 (9th Cir. 2006); Estate of Ashman v. Commi ssioner , 231 F.3d 541 (9th Cir. 2000); and LeFever v. Commissioner , 100 F.3d 778 (10th Cir. 1996). In this case, the taxpayer excluded the $X from her gross income in ---…
  18. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …fd. 220 Fed. Appx. 601 (9th Cir. 2007); Janis v. Commissioner, T.C.. Memo. 2004-117, affd. 461.F.3d 1080 (9th Cir. 2006), affd. 469 F.3d 256 (2d Cir. 2006). In the instant case, respondent has satisfied his burden of production because the record demonstrates.the presence of a substantial understatement of income tax a…
  19. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …able with only a fleeting reference to Ch evron , s ee, e.g. , Sturgeon v. Frost , 139 S. Ct. 1066, 1080 n.3 (2019), or without referencing Chevron at all, see, e.g ., Niz- Chavez v. Garland , 141 S. Ct. 1474, 1485 (2021) . And the Supreme Court has specifically stated that it “need not resort to Chevron deference . . …
  20. 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…