Brief Case
Pension Resource

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 114 T.C. 171 (not yet in the library — opens the official source)
99 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996
    … over to an Individual Retirement Account established for the benefit of Mr. Souris. The remaining $171,476 was ineligible to be rolled over, and appears to be attributable to overfunding the plan over the years due to what turned out to be erroneous actuarial assumptions. Thus, as stipulated by the parties, that $171,…
  2. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    50,854 100.0 32,650,854 0.20 6,530,171 Third Year 32,650,854 100.0 32,650,854 0.20 6,530,171 Three-Year Average 44,478,847 44,478,847 $8,895,769 Note: *In the first year, the opt-out notifications are assumed to be sent to all participants. The Department estimates that there are 68,134,832 policyholders between the ag…
  3. 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 …
  4. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …. [Page 10] On February 23, 1987, Respondent SA executed a second promissory note in the amount of $171,000.00 in favor of Brighton Bank (hereinafter "Loan No. 25-20148-4") and purchased CD No. 350 in the amount of $171,000.00; CD No. 350 was pledged as collateral for this loan.7 Exs. C20, C21 & C22. CD No. 350 was iss…
  5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    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…
  6. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …disclosures + $39,121,801 for rollover documentation + $20,008,658 for policies and procedures + $8,171,727 for retrospective review = $131,918,693. The burden in the subsequent years is estimated as: $574,609 for disclosures + $39,121,801 for rollover documentation + $15,053,951 for policies and procedures + $8,171,72…
  7. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …herwise have an opportunity to dispute the liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114 T.C. 604, 609 (2000). The phrase "underlying tax liability" includes the tax deficiency, additions to tax, and statutory interest. Katz v. Commissioner, 115 T.C. 329, 339 (2000). In determining whether to sustain the…
  8. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    s from petitioner's IRA's in the total amount of $181,481. Of this amount, petitioners reported $8,762 as the taxable amount. The Notice of Deficiency In the notice of deficiency, respondent determined that the difference between the amount distributed from petitioner's IRA's (i.e., $90,662.11 + $90,818.53 = $181,480.6…
  9. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …s related to Appeals review 170 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2025-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2025-4 171 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 171 .01 In general 171 …
  10. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    …951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually paid by him to Ada an…
  11. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ased employees 170 .09 Partial terminations 170 .10 Publication 794, Favorable Determination Letter 171 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 171 .01 Scope 171 .02 Complete information required 171 .03 Complete copy of plan and trust instrument and applicable amendments require…
  12. 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…
  13. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    See Parker v. Commissioner, T.C. Memo. 2012-66, 103 T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax- (continued...) - 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to assign error to any of respondent's determinations, asserting instead that he had no…
  14. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008
    …ly liable for the tax reported or reportable thereon . Sec . 6013(d)(3) ; Butler v . Commissioner , 114 T .C . 276, 282 (2000) . In certain circumstances a spouse may obtain relief under section 6015 from such liability . One type of relief under section 6015 is provided in section 6015(f) as equitable relief "for any …
  15. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    … revenue procedure 164 .03 Other guidance affecting this revenue procedure 165 .04 Updated annually 171 .05 Possible future updates related to Appeals review 171 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2024-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2024-4 171 PART I. GENERALLY …
  16. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
  17. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    … revenue procedure 167 .03 Other guidance affecting this revenue procedure 167 .04 Updated annually 171 .05 Possible future updates related to Appeals review 171 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2021-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2021-4 172 PART I. GENERALLY …
  18. 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…
  19. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    …mination letter 169 .05 Opinion letter 169 .06 Oral advice 170 .07 Nonbank trustee approval letters 171 .08 Compliance statement 171 .09 Advisory letter 171 SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE? 171 SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT…
  20. 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…