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78 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 124 T.C. No. 12 — Charles P. Stepnowski v. Commissioner
    IRCCourt RulingsApr 26, 2005related by meaning
    t, as follows: (a) General: Disposition of an action for declaratory judgment which involves the initial qualification of a retirement plan * * * will ordinarily be made on the basis of the administrative record, as defined in Rule 210(b)(12). Only with the permission of the Court, upon good cause shown, will any party…
  3. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    … $5,000 of compensation for the preceding year and the required notifications to employees. Section 117 of the SECURE 2.0 Act amends sections 408(p), 401(k)(11), and 414(v) of the Code to increase both the annual salary reduction contribution/elective contribution limit and the limit on additional catch-up contribution…
  4. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    w why the statute as enacted contains language different from that in the House and - 10 - 1 We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize this Court to grant a declaratory judgment include secs. 6234, 7428, 7477, 7478, and 7479. 2 Sec. 7503 a…
  5. T.C. Memo. 2016-110 — Kenneth L. Mallory & Larita K. Mallory v. Commissioner
    IRCCourt RulingsJun 6, 2016
    …ION 1. The IRS correctly determined that Kenneth Mallory received a life insurance distribution of $237,897.25, of which $150,397.25 was includable in the Mallorys' gross income for the 2011 taxable year. The IRS argues that the termination of the policy in 2011 resulted in the extinguishment of Kenneth Mallory's $237,…
  6. 90 FR 2645 — Catch-Up Contributions
    IRCProposed Rules (FR)Proposed Jan 13, 2025
    …uirements for certain catch-up eligible participants pursuant ( printed page 2646) to sections 109, 117, and 603 of Division T of the Consolidated Appropriations Act, 2023, Public Law 117-328, 136 Stat. 4459 (2022), known as the SECURE 2.0 Act of 2022 (SECURE 2.0 Act). This document also proposes conforming amendments …
  7. 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…
  8. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    … and benefits managers familiarize with the changes to the VFC Program and Exemption (first year) 1,237 2 2,474 $124.75 $308,632 Total 1,237 2,474 308,632
  9. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    y revoked or modified if the transaction is completed without reliance on the letter ruling 237 .10 Taxpayer may request that retroactivity be limited 237 PART IV. USER FEES SECTION 30. WHAT ARE THE USER FEE REQUIREMENTS FOR REQUESTING ADVICE FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 237 .01 Legislation authorizing u…
  10. 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…
  11. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  12. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002
    …ot exclude the 1996 NYSL payment from income under section 72(b)(1). F. Whether Petitioner Had a $4,237 Net Operating Loss Carryover for 1996 Petitioner contends that he may carry over to 1996 a $4,237 net operating loss which resulted from investment losses from his rental property in previous years. We disagree. Peti…
  13. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …additional conferences 236 .06 Requires written confirmation of information presented at conference 237 .07 May schedule a pre-submission conference 237 .08 May schedule a conference to be held by telephone 237 SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE? 237 .01 Has same effect as a determination letter 237 .02 …
  14. 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…
  15. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …il, 3M Company, and 3M IPC for the 2006 year is $165,783 (equal to $4,283,153 minus an offset of $4,117,370 for unreimbursed research - and -develop ment expenses (R & D offset )) . We interpret the term “minimum section 482 adjustment” to be the minimum section 482 adjustment that would be made if petitioner were to p…
  16. PLR 201626003 — Exceptions
    IRCPrivate Letter RulingsJun 24, 2016
    …been distribu ted to participants in accordance with the terms of the plan. Under Revenue Ruling 79-237, 1979-2 C.B. 190 (Rev. Rul. 79-237), once applicable, the minimum funding standards described in section 412 apply to a pension plan through the date of its termination. Rev. Rul. 79-237 defines the date of terminati…
  17. 78 FR 35754 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Jun 14, 2013
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 237, as set forth below, is added to the table. Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annuities (pe…
  18. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  19. 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
    …ch user fees apply 236 .03 Requests and other actions that do not require the payment of a user fee 237 .04 Exemptions from the user fee requirements 237 .05 User fees under EPCRS 237 .06 Requests involving multiple offices, fee categories, issues, transactions, or entities 237 .07 Method of payment 238 .08 Transmittal…
  20. 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
    …36 .03 Advisory and opinion letters 236 .04 VCP compliance statements – electronic submissions only 237 SECTION 32. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS? 237 SECTION 33. EFFECTIVE DATE 237 SECTION 34. PAPERWORK REDUCTION ACT 237 DRAFTING INFORMATION 238 APPENDIX A-SCHEDULE OF USER FEES 239 .0…