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104 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    119 1 $63 $43,625,000   Non-Complex Service Providers 9,000 3 119 13 63 10,403,000   Complex Service Providers 1,000 24 119 80 63 7,511,000 2012 Plans 94,000 119 1 63 5,911,000   Non-Complex Service Providers 700 3 119 13 63 867,000   Complex Service Providers 100 24 119 80 63 626,000 Total for 2011 61,539,000 Total fo…
  2. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
  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. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013
    …-Sharing Plans, IRAs, Insurance Contracts, etc., from Ameriprise, reporting an IRA distribution of $157,074 and tax withheld of $2,500. Petitioner failed to timely file a Form 1040, U.S. Individual Income Tax Return, for 2006. Respondent prepared a substitute for return pursuant to section 6020(b). On the basis of the …
  5. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    agreement requires 60 days’ notice, respondent did not issue statutory notices until December 1, 1987, more than 60 days after the date of the letter. Moreover, that respondent did not comply, in exact detail, with his own internal operating procedures does not affect the resolution of the issue presented by petitioner…
  6. 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
    …6. AREAS COVERED BY AUTOMATIC APPROVAL PROCEDURES 156 SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES 157 SECTION 8. EFFECTIVE DATE 157 SECTION 9. PAPERWORK REDUCTION ACT 157 DRAFTING INFORMATION 157 SECTION 1. PURPOSE AND NATURE OF CHANGES .01 Purpose.
  7. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …ated 3,149,048 uninsured (or self-pay) individuals who receive a written good faith estimate × 5% = 157,452 uninsured (or self-pay) individuals who request a mailed good faith estimate of expected charges. Back to Citation 291.  The burden is estimated as follows: 157,452 good faith estimates × 0.25 hours = 39,363 hour…
  8. 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
    …ns, volume submitter plans, and prototype plans 156 .02 Employee Plans Compliance Resolution System 157 .03 Chief Counsel 157 SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 157 .01 In general 157 .02 Certain information re…
  9. 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…
  10. 83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Nov 15, 2018
    sacred. 119 Congr. Rec. S5723 In support of the same protections when they were debated in the U.S. House, Representative Margaret Heckler (R-MA) [15] likewise observed that “the right of conscience has long been recognized in the parallel situation in which the individual's right to conscientious objector status in ou…
  11. 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…
  12. 82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Oct 13, 2017
    ed. 119 Congr. Rec. at S5723. In support of the same protections when they were debated in the U.S. House, Representative Margaret Heckler (R-MA) [21] likewise observed that “the right of conscience has long been recognized in the parallel situation in which the individual's right to conscientious objector status in ou…
  13. T.C. Summary Opinion 2003-103 — Santos M. & Ingrid I. Castillo v. Commissioner
    IRCCourt RulingsJul 24, 2003related by meaning
    1 Unless otherwise indicated, section references hereafter are to the Internal Revenue Code in effect for the year at issue. T.C. Summary Opinion 2003-103 UNITED STATES TAX COURT SANTOS M. AND INGRID I. CASTILLO, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4698-02S. Filed July 24, 2003. Sant…
  14. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  15. 81 FR 64700 — Missing Participants
    PBGCProposed Rules (FR)Proposed Sep 20, 2016
    …tracted out (80 percent of 6,600 hours) is estimated at about $829,000, based on an hourly rate of $157 (5,280 hours at $157 per hour). This estimated cost of $157 per hour is based on the following assumptions: Wage rates account for approximately 70 percent of total labor costs, with the remaining 30 percent attribut…
  16. 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…
  17. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  18. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    … revenue procedure 154 .03 Other guidance affecting this revenue procedure 154 .04 Updated annually 157 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2019-4? 157 .01 In general 157 .02 Changes made to Revenue Procedure 2019-4 157 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PR…
  19. 157 T.C. No. 10 — Andrew McNulty & Donna McNulty v. Commissioner
    IRCCourt RulingsNov 18, 2021
    …887 F.3d 511, 523 (1st Cir. 2018), rev’g Sum m a Holdings, Inc. v. Com m issioner, T.C. Mem o. 2015-119; see also Sum m a Holdings, Inc. v. Com m issioner, 848 F.3d 779, 785 (6th Cir. 2017), rev’g T.C. Mem o. 2015-119. Benenson involved whether the Roth IRA’s receipt of DISC dividends was an excessive contribution in v…
  20. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    6,367,005 × 49%) = 3,119,832. Back to Citation 39.  Deloitte, Regulation Best Interest: How Wealth Management Firms are Implementing the Rule Package, (March 6, 2020). This report was released before Regulation Best Interest was effective, so more broker-dealers may now document rollover recommendations. As such, this …