IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
Notice 2004-78 — Actuarial assumptions; distributions under section 101 of Pension Funding Equity Act of 2004. This notice provides guidance in question and answer format on th… IRCNoticesNov 29, 2004
…olating the requirements of § 411(d)(6) of the Code and section 204(g) of ERISA pursuant to section 101(c) of PFEA ’04? A-6. Under section 101(c)(1) of PFEA ’04, a plan that is amended pursuant to any change made by section 101 does not fail to meet the requirements of § 411(d)(6) of the Code and section 204(g) of ERIS…
IRCRegulationsJan 19, 2017
(h)(1) (1) In general. Section 101(d) shall not apply to interest payments on any amount held by an insurer under an agreement to pay interest thereon (see sections 101(c) and 101(d)(4) and § 1.101-3). On the other hand, both section 101(c) and section 101(d) may be applicable to payments received under a single life i…
Notice 2012-46 — This notice provides guidance in the form of questions and answers with respect to the notice requirements of section 101(j) of the Employee Retirement Income … IRCNoticesJul 23, 2012
…ble contingent event to occur (for example, a decision to shut down a plant). No additional section 101(j) notice is required with respect to the unpredictable contingent event benefit under A-3 of this notice if this A-6(a) requires a section 101(j) notice with respect to that unpredictable contingent event benefit ea…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
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…
IRCCourt RulingsFeb 9, 2023
…Act of 1936 without change. Revenue Act of
1938, ch. 289, sec. 45, 52 Stat. at 474.
N. R
egulations 101
In 1939, the Treasu ry Department promulgated art. 45-1,
Regulations 101, Regulations 101 Relating to the Income Tax Under the
Revenue Act of 1938 , at 188- 190 (Gov’t Prtg. Off. 1939), which related to
section 45 of…
75 FR 70625 — Annual Funding Notice for Defined Benefit Plans ERISAProposed Rules (FR)Proposed Nov 18, 2010
blished a final regulation implementing the requirements of section 101(f) of ERISA as amended by PFEA '04.
See 29 CFR 2520.101-4.
Back to Citation
2. Prior to the applicability date of the PPA amendments to section 101(f) of ERISA, a multiemployer plan was required to furnish a funding notice consistent with § 2520.1…
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…
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…
80 FR 5626 — Annual Funding Notice for Defined Benefit Plans ERISAFinal Rules (FR)Feb 2, 2015
…nges to paragraph (d)(3) and the appendix of § 2520.104b-10 at this time.
F. Removal of 29 CFR 2520.101-4
In 2004, the Pension Funding Equity Act (PFEA '04), Public Law 108-218, amended title I of the Employee Retirement Income Security Act of 1974 (ERISA) by adding section 101(f), which required multiemployer defined …
IRCCourt RulingsJan 14, 2013related by meaning
ALS
T.C. Memo. 2013-10
UNITED STATES TAX COURT
THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners
V.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013.
1481-10.
R determined that a corporation's compensation packages for its
owner-employees were unreasonabl…
IRCCourt RulingsAug 6, 1991related by meaning
…(1990), on appeal (Fed. Cir., Nov. 1, 1990).
The Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388, while maintaining this option for a severely limited class of eligible individuals, suspended it for 5 years for the vast majority of CSRS employees.
The portion of sec. 72(e) involved herein rea…
IRCRegulationsJul 26, 2016
(a) (a) Applicability of section 101(c). Section 101(c) provides that if any amount excluded from gross income by section 101(a) (relating to life insurance proceeds) or section 101(b) (relating to employees' death benefits) is held under an agreement to pay interest thereon, the interest payments shall be included in …
IRCRegulationsJan 19, 2017
…nd illustrated in subparagraph (2) of this paragraph, the exclusion from gross income under section 101(b) also applies (but only to the extent provided in the next sentence) to amounts with respect to which the deceased employee possessed, immediately before his death, a nonforfeitable right to receive the amounts whi…
IRCRegulationsJul 9, 2026
(a) (a) Except as otherwise provided in paragraph (h)(4) of § 1.101-4, the provisions of section 101 of the Internal Revenue Code of 1954 and §§ 1.101-1, 1.101-2, 1.101-3, and 1.101-4 are applicable only with respect to amounts received by reason of the death of an insured or an employee occurring after August 16, 1954…
FAB 2025-02 — ERISA’s Annual Funding Notice Requirements Following SECURE 2.0 ERISADOL Field Assistance BulletinsApr 30, 2025
single-employer plan continue to rely on the model notice found in Appendix A of 29 CFR 2520.101-5 for notice years beginning after December 31, 2023? No. The model notice in Appendix A of 29 CFR 2520.101-5 no longer complies with section 101(f) of ERISA, as amended. However, a plan administrator of a single-employer p…
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…
IRCRegulationsJul 9, 2026
…ch death, the amounts to be excluded from gross income may be affected by the provisions of section 101 (c) (relating to amounts held under agreements to pay interest) or section 101(d) (relating to amounts payable at a date later than death). See §§ 1.101-3 and 1.101-4. However, neither section 101(c) nor section 101(…
IRCCourt RulingsMar 3, 2016related by meaning
nal tax. Respondent now concedes that petitioner is not liable for the
section 72(t) 10% additional tax under the "Turnover Order" and seeks a reduced deficiency and a reduced accuracy-related penalty.
On December 16, 2013, petitioner contacted the Center for Economic
Progress Low-Income Taxpayer Clinic (clinic) to dis…