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75 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    …m our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 U.S .C. sec. 482 (1976), as amended by the Tax Reform Act of 1976, Pub. …
  2. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989★ strong match
    …eral Explanation of the Revenue Act of 1978, p. 74 (Comm. Print 1979). The Congress amended section 131 of R.A. 1978 by section 252 of TEFRA, Pub. L. 97-248, 96 Stat. 324, 532. This provision made the amendments made by section 131 of R.A. 1978 inapplicable to qualified State judicial plans. On its facé, the language o…
  3. 88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Feb 2, 2023
    …)(1)(ii)(B) and (c)(1)(ii)(B), 29 CFR 2590.715-2713A(b)(1)(ii)(B) and (c)(1)(ii)(B), and 45 CFR 147.131(d)(1)(ii)(B) of the current rules, which are redesignated as 26 CFR 54.9815-2713A(b)(1)(ii)(B) and (c)(1)(ii)(C), 29 CFR 2590.715-2713A(b)(1)(ii)(B) and (c)(1)(ii)(C), and 45 CFR 147.131(b)(1)(ii)(B) in these propose…
  4. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  5. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …th regard to the nonforfeitability of employee benefits. Employee Retirement Income Security Act of 1974, Pub. L. 93-406, 88 Stat. 829, sec. 203. On Sept. 10, 1974, shortly after the enactment of ERISA, the Internal Revenue Service issued T.I.R. 1308 published as Rev. Proc. 74-38, 1974-2 C.B. 492, which covered the pro…
  6. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …ax Regs., "[n]o deduction for depreciation is allowable with respect to goodwill." However, section 197 provides for the amortization of the acquisition cost of certain intangibles, including goodwill, over a fixed 15-year period. Sec. 197(a), (d)(1)(A). An amortizable section 197 intangible includes any section 197 in…
  7. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    …f 1954, as in effect during the tax year in issue, unless otherwise noted. In a letter dated Dee. 7,1978, an appeals officer objected to the plan in its original form because, in part, the plan contained no provision requiring full vesting upon termination or upon complete discontinuance of contributions or preventing …
  8. 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
    sts 196 .14 Submission of related plans 196 .15 Withdrawal of requests 197 .16 Right to status conference 197 .17 How to request status conference 197 SECTION 11. WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 197 .01 Requesting determination letters 197 .02 Forms 198 .03 Appl…
  9. 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…
  10. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …e of final determination 196 SECTION 22. WHAT ARE THE STEPS FOR EXHAUSTING ADMINISTRATIVE REMEDIES? 197 .01 In general 197 .02 Steps for exhausting administrative remedies 197 .03 Applicant’s request for § 7805(b) relief 197 .04 Interested parties 197
  11. 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
    …mination Letter 196 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 197 .01 Scope 197 .02 Complete information required 197 .03 Complete copy of plan and applicable amendments required 197 .04 Separate application for each single § 414(l) plan (qualified plans only) 197 .05 Prior letters…
  12. Rev. Proc. 2015-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 2, 2015
    Rev. Proc. 2015–6 TABLE OF CONTENTS SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE? 197 .01 Purpose of revenue procedure 197 .02 Organization of revenue procedure 197 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO THIS PROCEDURE? 197 .01 In general 197 .02 Other changes 197 .03Other guidance 198 PART I. PROCEDURES…
  13. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    …(2), Income Tax Regs., for determining whether a partial termination has occurred. H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 300; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80, 129.
  14. 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
    … determination letters 196 .02 Forms 196 .03 Application must include a copy of plan and amendments 197 .04 Restatements required 197 .05 Section 414(x) combined plans 197 SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION? 197 .01 Eligibil…
  15. 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
    …ee relationship 196 .11 Incomplete applications 196 .12 Effect of failure to disclose material fact 197 .13 Where to file requests 197 .14 Submission of related plans 197 .15 Withdrawal of requests 197 .16 Right to status conference 197 .17 How to request status conference 198 .18 Correct format required 198 SECTION 11…
  16. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …o act on request for § 7805(b) relief 196 SECTION 23. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 197 .01 May be relied on subject to limitations 197 .02 Scope of reliance on determination letter 197 .03 Effect of subsequent publication of revenue ruling, etc. 197 .04 Effect of subsequent amendment by employer 197 .0…
  17. 75 FR 6857 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Feb 12, 2010
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 197, 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. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    …t the term “parties in interest” includes a broader range of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure.
  19. T.C. Memo. 2003-249 — James Christian Jensen v. Commissioner
    IRCCourt RulingsAug 19, 2003
    …d from Vanguard Fiduciary Trust Co. (Vanguard) two retirement plan distributions in the amounts of $131,555 ($131,555 retirement plan distribution) and $42,704 ($42,704 retirement plan distribution), respectively. Vanguard issued to petitioner Form 1099-R, Distributions From - 3 - 2 The actual amount that petitioner de…
  20. 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 .