Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 141 T.C. 173 (not yet in the library — opens the official source)
86 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  2. 84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
    IRCFinal Rules (FR)Nov 1, 2019
    …pursuant to § 3.172(d) is subject to the supplementary leverage ratio disclosure requirement at § 3.173(a)(2). (e) A Category III national bank or Federal savings association that is required to calculate a countercyclical capital buffer pursuant to § 3.11 is subject to the disclosure requirement at Table 4 to § 3.173,…
  3. 81 FR 71019 — Electronic Notice of Liquidation
    IRCProposed Rules (FR)Proposed Oct 14, 2016
    …tion, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(ii). PART 173—ADMINISTRATIVE REVIEW IN GENERAL 6. The general authority citations for part 173 continues to read as follows: Authority: 19 U.S.C. 66, 1501, 1520, 1624. 7. Revise § 173.4a to read as follows: § 173.4a Refund of exce…
  4. 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
    …Review of determination letters 172 SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 173 .01 Scope of this section 173 .02 Scope of determination letters 173 .03 Design-based safe harbor 173 .04 Governmental plans under § 414(d) 173 .05 Church plans under § 414(e) 173
  5. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …ndent Producer and two hours for a legal professional at an insurer, resulting in an hour burden of 173,535 hours and an equivalent cost of $28.7 million.[106] Table 14—Hour Burden and Equivalent Cost Associated With the Recordkeeping Requirement Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burd…
  6. 81 FR 89375 — Electronic Notice of Liquidation
    IRCFinal Rules (FR)Dec 12, 2016
    …ation, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(i). PART 173—ADMINISTRATIVE REVIEW IN GENERAL 6. The general authority citation for part 173 continues to read as follows: Authority: 19 U.S.C. 66, 1501, 1520, 1624. 7. Revise § 173.4a to read as follows: § 173.4a Refund of exces…
  7. 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
    …d the request 172 .05 Pending letter ruling requests 172 .06 When to attach letter ruling to return 173 .07 How to check on status of request 173 SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER? 173 .01 In gen…
  8. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    112 T.C. No. 6 UNITED STATES TAX COURT GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18999-97. Filed February 22, 1999. H and W, who were both disqualified persons within the meaning of sec. 4975, I.R.C., borrowed $340,000 from the qualified pension plan…
  9. 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
    …) 172 .05 Church plans under § 414(e) 172 .06 Tax treatment of certain contributions under § 414(h) 173 .07 Other limits on scope of determination letter 173 .08 Leased employees 173 .09 Partial terminations 173 .10 Publication 794, Favorable Determination Letter 173 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUES…
  10. 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 .
  11. 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
    …BLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 173 .01 In general 173 .02 Letter ruling 173 .03 Closing agreement 173 .04 Determination letter 173 .05 Opinion letter 173 .06 Oral advice 174 .07 Nonbank trustee approval letters 174 .08 Compliance statement 175 .09 Adv…
  12. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    ALS T.C. Memo. 2013-10 UNITED STATES TAX COURT THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners V. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013. 1481-10. R determined that a corporation's compensation packages for its owner-employees were unreasonabl…
  13. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  14. 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
    ….03 Chief Counsel 172 .04 Determination letters not issued for requests for minimum funding waivers 173 SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 173 .01 In general 173
  15. 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
    …evenue procedure 169 .04 Updated annually 172 .05 Possible future updates related to Appeals review 173 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2022-4? 173 .01 In general 173 .02 Changes made to Revenue Procedure 2022-4 173 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PR…
  16. 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…
  17. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  18. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ties section. Back to Citation 737.  This is estimated as: (500,000 Retirement Investors × 28.2%) = 141,000 paper disclosures. Note, the total values may not equal the sum of the parts due to rounding. Back to Citation 738.  This is estimated as: (141,000 paper disclosures × (2 minutes ÷ 60 minutes)) = 4,700 hours. A l…
  19. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein, Decision will be entered for the respondent. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
  20. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …