Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 91 T.C. 686 (not yet in the library — opens the official source)
92 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2019-19 — Lily Hilda Soltani-Amadi & Bahman Justin Amadi v. Commissioner
    IRCCourt RulingsAug 8, 2019
    …ption of Qualified Trusts) (Westlaw 2019). - 7 - distributed to Ms. Soltani-Amadi in 2015 (i.e., $6,686) taxable to her for that year pursuant to section 72.3 See sec. 402(a). As a general rule, a distribution from a section 401(k) retirement plan is fully taxable pursuant to section 72 because the participant's contri…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  3. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …ses listed below that have not been conceded: Iten1 Reported Disallowed Conceded At issue Wages $68,686 $68,686 $65,208 $3,478 Meals and entertainment 2,489 2,489 --- 2,489 Travel 2,456 2,456 --- 2,456 Taxes and licenses 15,317 15,317 15,317 --- Rent/lease 21,135 21,135 21,135 ---
  4. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012★ strong match
    …for the determination of a taxpayer's correct tax liability. Petzoldt v. Commissioner, 92 T.C. 661, 686 (1989). If a taxpayer fails to maintain or does not produce adequate books and records, the Commissioner is authorized to reconstruct the taxpayer's income. Sec. 446(b); Petzoldt v. Commissioner, 92 T.C. at 686-687. …
  5. IRCCourt RulingsAug 3, 1979related by meaning
    istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
  6. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  7. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997★ strong match
    there are some matters which require some testimony. If that is the case, it's clear that the Court cannot rule in your favor on the summary judgment motion. You can't get a dispositive answer, which is what you want. So the next step is trial. D. Entry of Appearance by Petitioners' Counsel On July 18, 1994, petitione…
  8. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …inted page 65509) would be 2,527,110 hours with an equivalent associated cost of approximately $230,686,747. Table 13A—Estimated One-Time Cost and Hour Burden per Health Insurance Issuer or TPA for the Out-of-Network Allowed Amount File Occupation Burden hours per respondent Labor cost per hour Total cost per responden…
  9. T.C. Summary Opinion 2006-11 — Richard Bradley v. Commissioner
    IRCCourt RulingsJan 26, 2006
    …compensation of $3,557 in tax year 2001. Respondent concedes that petitioner is not liable for a $1,686 accuracy-related penalty under sec. 6662(a). Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a $9,831 deficiency in pe…
  10. 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…
  11. 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…
  12. 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…
  13. 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…
  14. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    ERISACourt RulingsAug 31, 2026
    …don, 166 F.4th 645, 649 (7th Cir. 2026); accord Meyer v. Duluth Bldg. Trades Welfare Fund, 299 F.3d 686, 689 (8th Cir. 2002) ; Penn v. Howe - Baker Engrs., Inc., 898 F.2d 1096, 1100 (5th Cir. 1990). III. Liu argues that the Complaint plausibly alleg es
  15. 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…
  16. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …/​products/​gao-17-259. Back to Citation 29.  The total number of credit unions is calculated as: 4,686 federally insured credit unions/(100%-2% of credit unions that are privately insured) = 4,782 total credit unions. The number of private credit unions is estimated as: 4,782 total credit unions − 4,686 federally insu…
  17. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …​products/​gao-17-259. Back to Citation 356.  The total number of credit unions is calculated as: 4,686 federally insured credit unions/(100%−2% of credit unions that are privately insured) = 4,782 total credit unions. The number of private credit unions is estimated as: 4,782 total credit unions − 4,686 federally insu…
  18. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  19. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …lroad siding_ 14, 423. 00 4, 200. 74 10, 222. 26 Driveway and parking lot_ 4, 572. 28 1, 885. 97 2, 686. 31 Machinery and equipment_ 468, 797. 15 210, 393. 80 258, 403. 35 Office furniture and fixtures_ 10, 267. 51 3, 327. 46 6, 940. 05 Office machines— 15, 590. 85 8, 989. 54 6, 601. 31 Truck and tractor. 4, 362. 38 3,…
  20. 85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 7, 2020
    …um 3 if monthly benefit at URA is— High 4 if monthly benefit at URA is greater than— From— To— 2022 686 686 2,896 2,896 2023 701 701 2,963 2,963 2024 718 718 3,031 3,031 2025 734 734 3,100 3,100 2026 751 751 3,172 3,172 2027 768 768 3,245 3,245 2028 786 786 3,319 3,319 2029 804 804 3,396 3,396 2030 822 822 3,474 3,474 …