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1. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996related by meaning
   ies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), petitioner is not liable for the excise tax imposed by section 4980A for 1989. For 1990, petitioner withdrew an amount in excess of $150,000 from his IRA with First National. Accordingly, - 28 - 20 See supra note 15 and accompanying text. Further, …
2. T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations …
   IRCTreasury DecisionsAug 6, 2007related by meaning
   INCOME TAX Rev. Rul. 2007-50 Rev. Rul. 2007-50 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2007. T.D. 9329 T.D. 9329 Final regulations under sect…
3. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
   IRCCourt RulingsJun 24, 2003related by meaning
   tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
4. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
   IRCCourt RulingsJan 16, 2002related by meaning
   470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
5. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
   IRCCourt RulingsFeb 12, 2014
   …We conclude here, as we did in Stovall, that it is appropriate to use the regulations under section 1033(a) as guidance in determining whether the Secretary was "notified" under section 4979A(e)(2)(D) of the ownership that gives rise to the excise tax under section 4979A(a).'° 9Sec. 1034 was repealed effective May 6, 1…
6. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
   IRCRevenue ProceduresDec 30, 2024
   …f the contractual obligation. (97) Section 1001.—See section 3.01(13) and (14), above. (98) Section 1033.—Involuntary Conversions.—Whether the replacement or proposed replacement of compulsorily or involuntarily converted property does or does not qualify under § 1033(a), if the taxpayer has already filed a Federal tax…
7. 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…
8. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
   IRCCourt RulingsNov 17, 2016
   …at "[a] taxpayer need not make an affirmative election regarding the nonrecognition of gain under § 1033(a) of the 1954 Code." But what petitioner neglects to mention is that the following sentence in that decision reads: "The regulations explicitly state that a failure to include gain on an involuntary conversion in g…
9. 68 T.C. 433 — Newman v. Commissioner
   IRCCourt RulingsJun 29, 1977
   …hich was to aid States in borrowing funds. Thus, in American Viscose Corp. v. Commissioner, 56 F.2d 1033 (3d Cir. 1932), affg. 19 B.T.A. 937 (1930), cert. denied 287 U.S. 615 (1932), it was stated:
10. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    … in Phi Delta Theta Fraternity v. Commissioner , 887 F.2d 1302, 1307 (6th Cir. 1989), affg. 90 T.C. 1033 (1988): “Section 512(a)(3)(B), however, does allow reasonable costs actually spent in administering a tax-exempt activity to be included in ‘exempt function income.’” We find the Trustee’s reliance on that statement…
11. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    IRCCourt RulingsJun 6, 2005related by meaning
    a matter of legislative grace, and the burden of clearly showing the right to the claimed deduction is on the taxpayer. INDOPCO, Inc. v. Commissioner , 503 U.S. 79, 84 (1992). We are bound by the Internal Revenue Code, and it is within the province of the legislature to decide the circumstances of inclusion, deductions…
12. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …412(c)(3), 6059, and 7701(a)(35) were added to the Internal Revenue Code by ERISA sections 1013(a), 1033(a), and 3043, 88 Stat. 914, 947, 1003, to apply for plan years beginning after December 31, 1975. ERISA had a significant impact on pension plans, and one of its objectives was to place reliance upon enrolled actuar…
13. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
14. 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 …
15. ERISA § 518 (29 U.S.C. § 1148) — Authority to postpone certain deadlines by reason of Presidentially declared disaster or terroristic or military actions
    ERISACode / StatuteJan 6, 2025
    …on with respect to such plan, affected by a Presidentially declared disaster (as defined in section 1033(h)(3) of title 26) 1 a terroristic or military action (as defined in section 692(c)(2) of such title), or a public health emergency declared by the Secretary of Health and Human Services pursuant to section 247d of …
16. ERISA § 4002(i) (29 U.S.C. § 1302) — Pension Benefit Guaranty Corporation
    PBGCCode / StatuteJan 6, 2025
    …on with respect to such plan, affected by a Presidentially declared disaster (as defined in section 1033(h)(3) of title 26) or a terroristic or military action (as defined in section 692(c)(2) of such title), the corporation may, notwithstanding any other provision of law, prescribe, by notice or otherwise, a period of…
17. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
18. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …s discretion.” New Hampshire v. Maine, 532 U.S. 742, 750 (2001) (quoting Russell v. Rolfs, 893 F.2d 1033, 1037 (9th Cir. 1990)). Judicial estoppel is “‘not reducible to any general formulation of principle,’ though the inquiry is typically informed by several factors.” Grochocinski v. Mayer Brown Rowe & Maw, LLP, 719 F…
19. 99 T.C. 9; 99 T.C. No. 2 — Vinson & Elkins v. Commissioner
    IRCCourt RulingsJul 14, 1992
    …412(c)(3), 6059, and 7701(a)(35) were added to the Internal Revenue Code by ERISA sections 1013(a), 1033(a), and 3043, 88 Stat. 914, 947, and 1003, to apply for plan years beginning after December 31, 1975. ERISA had a significant impact on pension plans, and one of its objectives was to place reliance upon enrolled ac…
20. 109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner
    IRCCourt RulingsDec 29, 1997
    … (3d Cir. 1965), which involved nonrecognition of gain upon an involuntary conversion under section 1033. Petitioner also quotes a similar definition - 12 - of an involuntary conversion in Grant Oil Tool Co. v. United States , 180 Ct. Cl. 620, 381 F.2d 389, 395 (1967), which provides that an involuntary conversion of p…