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82 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …Preparation (In-House) 77,012 = 770,117 Plans × 10% Not Using a Service Provider 1 181.06 77,012 13,943,731 Adding Contact and Plan Information to Drafted Explanations 693,105 = 770,117 Plans × 90% Using a Service Provider 5/60 70.29 57,759 4,059,862 Total 138,322 $18,646,718 Table 8—Cost for Distribution of New Paper …
  3. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …5 taxable distribution from his law firm's 401(k) plan; (3) whether petitioner is entitled to a $33,943 interest expense deduction; (4) whether petitioner is liable for an addition to tax for failure to timely file his 1991 Federal income t ax return pursuant to section 6651(a)(1); and (5) whethe r petitioner is liable…
  4. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …n ($79,812) by the number of third-party developers and other file users (300): $79,812 × 300 = $23,943,600. Back to Citation 210.  Annual storage savings of $57,355,200 is calculated by subtracting the total annual cost after file-size reduction ($23,943,600) from the total annual cost under current file-size assumpti…
  5. 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…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …297,798 13,949 311,747 20032 -0- 925,640 1,072 926,712 2004 -0- (917,045) -0- (917,045) 2005 -0- (3,943) -0- (3,943) Total 16,356,316 519,577 362,091 881,668 1The Court has derived this column of information from the reported taxable income and depreciation amounts on the Forms 1120. 2The facility was sold in 2002, and…
  7. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  8. 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…
  9. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …t promised lifetime benefits will indeed survive for a lifetime.” Stone v. Signode Indus. Grp. LLC , 943 F.3d 381, 385 (7th Cir. 2019) (emphasis in original) ; s ee Tackett, 574 U.S. at 442 (noting that “a collective-bargaining agreement [may] provid[e] in explicit terms that certain benefits continue after the agreement…
  10. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …ted dividend income of $100,152, $99,916, and $80,510 and paid Federal income taxes of $22,063, $21,943, and $15,349,v respectively. TDH reported dividend income of $100,152, $99,916, and $80,510 and paid Federal income taxes of $22,063, $21,943, and $15,349, respective.ly. TLS reported dividend income of $100,152, $99…
  11. 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…
  12. T.C. Summary Opinion 2003-157 — Darrell R. Fulcher v. Commissioner
    IRCCourt RulingsOct 21, 2003
    …ified individual retirement accounts: Nationwide Life Insurance Co. $5,000.00 First National Bank 3,943.33 Total distributions $8,943.33 Both institutions issued to petitioner Forms 1099-R,
  13. 64 T.C. 331 — Aero Rental v. Commissioner
    IRCCourt RulingsMay 29, 1975
    …b) was amended by section 1023 of the Employee Retirement Income Security Act of 1974.88 Stat. 829, 943. It now provides: (b) Certain Retroactive Changes in Plan. — A stock bonus, pension, profit-sharing, or annuity plan shall be considered as satisfying the requirements of subsection (a) for the period beginning with …
  14. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    ax of $3,000.60 because she received.the distributions before she attained age 59-1/2 and the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v). Discussion Summary judgment is intended to.expedite litigation and avoid unnecessary and expensive trials and may be granted where the…
  15. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  16. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  17. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  18. 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…
  19. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …ue Code that "limit or prohibit interest under certain conditions". IA sec. 2.01(2), 1960-2 C.B. at 943. These provisions create a type of interest called "restricted interest". R Some of the Code provisions that can give rise to restricted interest include sec. 172(b) (2002) (NOL carrybacks), amended by Tax Cuts and J…
  20. T.C. Memo. 1999-352 — Luisa Deal v. Commissioner
    IRCCourt RulingsOct 25, 1999related by meaning
    spondent's determination that she is liable for a 10-percent additional tax on her 1995 IRA distribution. Since petitioner fails to qualify for any of the statutory exceptions under section 72(t)(2), we hold that petitioner is liable for the 10-percent additional tax on distributions from a qualified retirement plan fo…