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82 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  2. 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…
  3. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    individual employer contributors to determine their deduction limits in the tenebrous context of overlapping tax and plan years. Consequently, section 404(a)(6), by its reference to section 404(a)(1) through (3), has an impact on section 413(b)(7). Petitioner maintains that, if an individual employer's tax treatment of…
  4. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the legislative intent, the rule of section 457(e)(1) does not apply and Foil’s 1981 employee contributions are not taxed until made available to him. Respondent maintains that section 252 of TEFRA removes “qualified State judicial plans” from the application of section 131 of R.A. 1978 but it does not provide any spec…
  5. 86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
    ERISAProposed Rules (FR)Proposed Oct 14, 2021
    …that there are 67,862 plans that will need to ensure compliance with the proposal. A labor rate of $138.41 is used for a lawyer. The cost burden is estimated as follows: 4 hours * $138.41 = $553.64. Labor rates are based on DOL estimates from Labor Cost Inputs Used in the Employee Benefits Security Administration, Offi…
  6. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  7. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984★ strong match
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  8. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    by section 404(a)(6), and are therefore not deductible in that year. To reflect the foregoing and issues previously resolved, Decision will be entered under Rule 155 .
  9. 75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient…
    IRCFinal Rules (FR)Jul 23, 2010
    arket Total Enrollees (millions) 138.0 39.0 15.1 138.0 39.0 15.1 138.0 39.0 15.1 Non-Grandfathered Enrollees 24.4 6.9 6.0 44.5 12.6 9.7 61.0 17.2 11.8 Total Claims (millions) 248.9 70.4 61.5 453.8 128.3 98.5 622.4 175.9 120.6 Pre-Service: Claim Approved 6.3 1.8 1.6 11.6 3.3 2.5 15.9 4.5 3.1 Claim Denied 1.1 0.3 0.3 2.0…
  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. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  12. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
  13. 75 FR 65263 — Definition of the Term “Fiduciary”
    ERISAProposed Rules (FR)Proposed Oct 22, 2010
    …lars) Year Cost of legal review undiscounted (A) Total 3% discounting Total 7% discounting 2011 $10,138,000 $10,138,000 $10,138,000 2012 845,000 820,000 790,000 2013 845,000 796,000 738,000 2014 845,000
  14. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024
    is is estimated as (44,593,228 × 3.9%) + (67,781,000 × 28.2%) = 20,853,378 paper disclosures. Due to rounding values may not sum. Back to Citation 82.  This burden is estimated as: [(20,853,378 disclosures × (5 minutes ÷ 60 minutes hours)] = 1,737,781 hours. The labor cost is estimated as: [(20,853,378 disclosures × (5…
  15. 85 FR 72846 — Financial Factors in Selecting Plan Investments
    ERISAFinal Rules (FR)Nov 13, 2020
    5 DB plans; 93,033 DC Plans * 19% = 17,676 DC plans; 581,974 * 9% = 52,378 individual account plans with participant direction). Back to Citation 109.  The burden is estimated as follows: (8,905 DB plans * 0.01 * 2 hours) + (17,676 DC plans * 0.01 * 2 hours * 0.33) + (52,378 DC plans with participant direction * 0.01 *…
  16. 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…
  17. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013
    … from the IRA to CST.7 On or about August 19, 2005, Mr. Ellis received a second distribution of $67,138.81 from the section 401(k) account he had accumulated at Aventis Pharmaceuticals.8 9 As with the first distribution check, Mr. Ellis deposited the entire $67,138.81 into his IRA. On or about August 23, 2005, Mr. Elli…
  18. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …9.00 -0- 239.00 Legal & prof. 1,785.04 615.16 -0- 615.16 Mortg. interest 3,558.53 3,558.53 3,420.45 138.08 Repairs -0- 138.40 -0- 138.40 Taxes 424.00 424.00 509.04 (85.04) Utilities 107.97 310.05 107.97 202.08 Termite control 265.00 -0- -0- -0Home shield 450.00 -0- -0- -0Prop. mgt. 400.00 -0- -0- -0Federal Express 14.0…
  19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  20. PBGC Op. Ltr. 1993-2 — Withdrawal liability
    PBGCPBGC Opinion LettersJul 7, 1993
    …ately [*3] preceding the 3-year testi ng perio d. ER ISA § 42 06( a)(2 )(A) a nd (B ); 29 U .S.C. § 138 6(a) (2)(A ) and (B) . You ask whether the numerator of the fract ion is t he contribution base unit s for the plan y ear following the hypothet ical complete withdrawal (i. e., the second plan ye ar in the 3 -year t…