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…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
…le, corporate-level proceeding. However, the Small Business Job
Protection Act of 1996, Pub. L. No. 104-188, sec. 1307(c)(1), 110 Stat. at 1781,
repealed those provisions for taxable years beginning after December 31, 1996.
Respondent's adjustments to Environmental's income are therefore properly
before us in this proc…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…mount of retail deposits other than stable retail deposits or brokered deposits, described in § 249.104(c)(1) (row 6); (vii) The average weighted amount and, for each applicable maturity category, the average unweighted amount of sweep deposits, brokered reciprocal deposits, and brokered deposits provided by a retail c…
IRCCourt RulingsFeb 9, 2023★ strong match
of the $5,104,756
trademark royalty payment can be viewed as a $0 adjustment because
respondent agrees with the tax reporting of this amount by the 3M consolidated group. Equivalently, one can think of respondent’s position
on the tax treatment of the $ 5,104,756 trademark royalty payment as
comprising two separate ste…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
…amount of retail deposits other than stable retail deposits or brokered deposits, described in § __.104(c)(1) (row 6); (vii) The weighted amount and, for each applicable maturity category, the unweighted amount of brokered deposits provided by a retail customer or counterparty described in §§ __.104(c)(2), __.104(c)(3)…
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
.
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…tion (EBSA) considers employee benefit plans with fewer than 100 participants to be small entities.[115] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)…
ERISARegulationsApr 25, 2023
… with respect to the following:
(g)(1) (1) A totally unfunded welfare plan described in 29 CFR 2520.104-44(b)(1)(i);
(g)(2) (2) A welfare plan which meets the requirements of 29 CFR 2520.104-20(b);
(g)(3) (3) An apprenticeship or other training plan which meets the requirements of 29 CFR 2520.104-22;
(g)(4) (4) A pensi…
IRCCourt RulingsAug 6, 1991related by meaning
…n 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 reads as fol…
IRCCourt RulingsAug 24, 1995related by meaning
section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992).
In order to implement the views expressed herein,
An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…
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…
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
…nd (e), 3121(b)(8)(A), and 3401(a)(9).)
(24) Section 111.—See section 3.01(13), above.
(25) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s compensation claims is excluded from gro…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…n 100 participants to be small entities.[99] The basis of this definition is found in ERISA section 104(a)(2), which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under ERISA section 104(a)(3), the Secretary may also provide for exemptions or sim…
IRCProposed Rules (FR)Proposed May 13, 2026
…r than 100 participants to be small entities.[185] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…er than 100 participants to be small entities.[42] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… 100 participants to be small entities.[359]
The basis of this definition is found in ERISA Section 104(a)(2), which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under ERISA Section 104(a)(3), the Secretary may also provide for exemptions or sim…
IRCCourt RulingsMay 14, 2012
…ross income are construed narrowly.
See Commissioner v. Schleier, 515 U.S. 323, 328 (1995). Section 104 provides in pertinent part as follows:
SEC. 104. COMPENSATION FOR INJURIES OR SICKNESS.
(a) In General.-Except in the case of amounts attributable to
(and not in excess of) deductions allowed under section 213 (relat…
77 FR 74063 — Amendments to the Abandoned Plan Regulations ERISAProposed Rules (FR)Proposed Dec 12, 2012
…yee benefit plan with fewer than 100 participants. The basis of this definition is found in section 104(a)(2) of ERISA that permits the Secretary of Labor to prescribe simplified annual reports for pension plans that cover fewer than 100 participants. Under section 104(a)(3), the Secretary may also provide for exemptio…
IRCCourt RulingsJun 14, 1982related by meaning
d the correctness of respondent’s interpretation of the interplay of sections 72,104, and 105 and the regulations thereunder as applied to their case. What petitioners do challenge, however, is the constitutionality of sections 104(a)(4) and 105(d) in an effort to bring their disability payments within the exclusions f…