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79 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
  2. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …ly distribution to Ms. Zaklama from a retirement plan. On January 2, 1996, Ms. Zaklama withdrew $92,830 from her money market retirement account at California Federal Bank F.S.B. (CFB3568)." The bank issued Ms. Zaklama a Form 1099-R for 1996 reporting the distribution to her as an early withdrawal from a retirement pla…
  3. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …ranslate those operations into the reporting currency of the reporting entity. FASB, 2023, ASC par. 830-10-10-1. The assets and liabilities and other elements, such as revenues and expenses, of the financial statements of a foreign entity are translated to the reporting currency using a current exchange rate. FASB, 202…
  4. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …t income of $1,711, which must be included in 1987; and (4) they received an IRA distribution of $1,830, which they failed to report as income on their 1987 Federal income tax return. 2 Unless otherwise indicated, all section references are to
  5. 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…
  6. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  7. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …2022 1,959 1,959 37,440.0 73,344,960 $10,374,237,120 2023 1,959 1,959 24,440.0 47,877,960 6,611,791,830.97 2024 1,959 1,959 8,060.0 15,789,540 2,180,484,540.00 3 year Average 1,959 1,959 23,313 45,670,820 6,388,837,830.32 Table 9—Estimated Low-End Three Year Average Annual Hour Burden and Costs for All Issuers and TPAs…
  8. 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…
  9. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998★ strong match
    …is actually distributed to the employees. Sec. 402(a)(1); Ludden v. Commissioner , 68 T.C. 826, 829-830 (1977), affd. 620 F.2d 700 (9th Cir. 1980). However, if the trust fails to qualify under - 20 - 6 Sec. 401(a) provides, in pertinent part, as follows: SEC. 401(a). Requirements for Qualification.--A trust created or …
  10. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022★ strong match
    … re based on the determination that petitioner’s 4,586 shares of stock in the ESOP were worth only $830,392 and that TEOHC had paid the balance of the $26 million i n exchange for petitioner’s relinquishment of his interests under the CCA plan, the ISO plan, and the VEI pl an. Since none of those interests represent ed…
  11. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    … cents per page. The Department estimates that the total cost burden of the rule in 2010 will be $8,830,000 (approximately $8,810.000 for service providers and $21,000 for plans), and $1,435,000 (approximately $1,424,000 for service providers and $10,000 for plans in subsequent years. The three-year average cost burden…
  12. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …$50,078.05 ($50,440.40 - $362.35). The cost of insuring Dr. Hirshkowitz for the second year was $11,830.58, and, at the end of that year, the conversion credit balance was $81,793.61 ($39,661.58 + $50,440.40 - $11,830.58 + $3,522.21); the $3,522.21 is the interest of 4.5 percent earned on the conversion credit balance …
  13. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  14. PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
  15. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  16. 78 FR 72018 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 2, 2013
    …594 2,594 2016 627 627 2,651 2,651 2017 641 641 2,710 2,710 2018 655 655 2,769 2,769 2019 670 670 2,830 2,830 2020 685 685 2,893 2,893 2021 700 700 2,956 2,956 2022 715 715 3,021 3,021 2023 731 731 3,088 3,088 2024 or later 747 747 3,156 3,156 1 Table II-A. 2 Table II-B. 3 Table II-C. * * * * * Issued in Washington, DC…
  17. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    Motion for a Section 6673 Penalty Respondent submitted a motion for the imposition of a penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous,…
  18. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    ERISACourt RulingsAug 31, 2026
    …nge, under California law, “equity should regard the change as effected.” BankAmerica , 206 F.3d at 830 (quoting Pimentel v. Conselho Supremo De Uniao
  19. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
  20. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …3d at 384 (7th Cir. 2019) (citing Tackett, 574 U.S. at 435); see Barnett v. Ameren Corp. , 436 F.3d 830, 832–33 (7th Cir. 2006). Thus, to determine whether the retiree health benefit that