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93 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. IRCRegulationsJul 26, 2016
    …2.9 2.8 2.7 106 4.0 3.8 3.6 3.5 3.3 3.1 3.0 2.8 2.7 2.5 107 4.0 3.8 3.6 3.4 3.2 3.1 2.9 2.7 2.6 2.4 108 3.9 3.7 3.5 3.3 3.1 3.0 2.8 2.7 2.5 2.3 109 3.8 3.6 3.4 3.3 3.1 2.9 2.7 2.6 2.4 2.3 110 3.8 3.6 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 …
  2. 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…
  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. Notice 2008-7 — Diversification; transition rules; extension. This notice provides an extension of certain transitional rules with respect to the diversification requirements …
    IRCNoticesJan 22, 2008
    …employer securities that are not imposed on the investment of other assets of the plan. Notice 2006-107 provides transitional guidance with respect to § 401(a)(35). For example, Part III.D of Notice 2006-107 provides that a restriction or condition with respect to employer securities generally includes: (1) a restricti…
  5. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    the amount of $1,045,108 ($1,295,108 - $250,000). The stock sale may be depicted as follows: Amount owed MIT 80 by MPC from 1988 to (1992) $1,295,108 Claimed value of MIT Transportation Co., (250,000 ) Inc. stock given to MPC, then to MIT 80 Amount BBPA advised MIT 80 partners to 1,045,108 claim as a loss in 1992 The …
  7. 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…
  8. 86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCFinal Rules (FR)Feb 11, 2021
    …any's, or covered nonbank company's average amount of the NSFR derivatives asset amount under § 249.107(d)(1) and in the “weighted” cell, the covered depository institution holding company's, U.S. intermediate holding company's, or covered nonbank company's average amount of the NSFR derivatives asset amount under § 24…
  9. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    …rther detail below. Step 2: Calculation of Total Derivatives Asset and Liability Amounts Under § __.107(e) of the proposed rule, a covered company would sum all of its derivatives asset values, as calculated under § __.107(f)(1), to arrive at its “total derivatives asset amount” and sum all of its derivatives liability…
  10. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …criptions x $181.15 total average patient out-of-pocket and insurer expenditure per prescription = $108,831,984,000. This represents 16.3 percent of $667,000,000,000 total annual prescription expenditures. ( Source: 2022 Medical Expenditure Panel Survey, Agency for Healthcare Research and Quality, Department of Health …
  11. 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…
  12. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  13. 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…
  14. T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.…
    IRCTreasury DecisionsApr 30, 2007
    …Law 100-647 (102 Stat. 3342) (TAMRA), the Uruguay Round Agreements Act of 1994, Public Law 103-465 (108 Stat. 4809) (GATT), the Small Business Job Protection Act of 1996, Public Law 104-188 (110 Stat. 1755) (SBJPA), the Community Renewal Tax Relief Act of 2000, Public Law 106-554 (114 Stat. 2763) (CRA), the Economic Gr…
  15. REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie…
    IRCProposed Rules (FR)Proposed Jul 5, 2005
    …Law 100-647 (102 Stat. 3342) (TAMRA), the Uruguay Round Agreements Act of 1994, Public Law 103-465 (108 Stat. 4809) (GATT), the Small Business Job Protection Act of 1996, Public Law 104-188 (110 Stat. 1755) (SBJPA), the Community Renewal Tax Relief Act of 2000, Public Law 106-554 (114 Stat. 2763), the Economic Growth a…
  16. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  17. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013
    …solvent at the time, no part of the distribution is includible in gross income by virtue of section 108(a)(1)(B).7 Respondent argues that petitioners failed to prove that they were insolvent. But more fundamentally, respondent argues that because the surrender of the life insurance policy resulted in the full satisfact…
  18. 85 FR 72472 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions
    IRCFinal Rules (FR)Nov 12, 2020
    … 95 4.0 96 3.7 97 3.4 98 3.2 99 3.0 100 2.8 101 2.6 102 2.5 103 2.3 104 2.2 105 2.1 106 2.1 107 2.1 108 2.0 109 2.0 110 2.0 111 2.0 112 2.0 113 1.9 114 1.9 115 1.8 116 1.8 117 1.6 118 1.4 119 1.1 120+ 1.0 (c) Uniform Lifetime Table. The following table, referred to as the Uniform Lifetime Table, sets forth the distribu…
  19. T.C. Summary Opinion 2015-37 — Charles D. Trainito v. Commissioner
    IRCCourt RulingsJun 23, 2015
    …scharge of indebtedness occurs, the amount otherwise includable is excluded from gross income. Sec. 108(a)(1)(B). The amount excluded from gross income may not exceed the amount by which the taxpayer is insolvent. Sec. 108(a)(3). "Insolvent" within the meaning of section 108 is defined as the excess of a taxpayer's lia…
  20. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…