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75 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    owing differences: I --between the amounts of royalties and other expenses referred to in article 74 of the mentioned Law, credited or paid during the base-year, and the minimum percentages established for the respective deduction, according to (b) and (d); II--between the quotas for the purpose of forming depreciation…
  2. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    … or their partner to become pregnant.[152] As such, the Departments estimate that approximately 743,361 participants or beneficiaries in non-Federal employer-sponsored health plans aged 25 to 45 would seek medical assistance to become pregnant each year.[153] The Departments estimate an equal share would likely enroll …
  3. 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
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  4. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    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…
  5. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …e 1/1/91 1/1/92 1/1/93 1/1/94 1. Actuarial present value of projected benefits Active employees $13,361,586 $38,521,857 $62,860,146 $83,594,015 Retired employees 26,311,902 36,694,928 47,731,960 48,947,859 Total 39,673,488 75,216,785 110,592,106 132,541,874 2. Actuarial value of assets VEBA -0- 30,736,554 30,176,217 39…
  6. T.C. Summary Opinion 2006-74 — Charles M. Rideaux v. Commissioner
    IRCCourt RulingsMay 3, 2006
    … 1059 (7th Cir . 1982), affg . T .C . Memo . 1981-407) ; Stricker v . Commissioner , 54 T .C . 355, 361-362 (1970), affd . 438 F .2d 1216 (6th Cir . 1971) . They lend guidance to the interpretation of "indefinite" in this case . An employment is for an indefinite duration if its termination is not foreseeable or is not…
  7. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    ution for the taxable year, reduced (but not below zero) by (ii) 20 percent of the amount (if any) by which such total taxable amount exceeds $20,000. (E) Liability for tax. — The recipient shall be liable for the tax imposed by this paragraph. Sec. 402(e)(4)(A) provides in pertinent part: (4) Definitions and special r…
  8. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015
    …ite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd,
  9. T.C. Memo. 2008-201 — Joseph R. Banister v. Commissioner
    IRCCourt RulingsAug 27, 2008
    …e illegal - 4 - sales or reflecting the amount of proceeds the taxpayer actually received . Id . at 361-362 . The Court of Appeals refused to allow the presumption of correctness to attach, emphasizing the unfairness that would result if the Commissioner were allowed to affix the prejudicial label of drug dealer on the…
  10. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    … × ($47,000 + $50,000 + $52,000) ÷ 3], or $703.61 per month. The corresponding death benefit is $70,361.(iv) The excess of the death benefit over Participant A's accrued benefit as of January 1, 2010, is $20,694 (that is, $70,361 − $49,667). Because this part of the death benefit is not a function of Participant A's ac…
  11. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …0053. Affected Public: Businesses or other for-profits, Not-for-profit institutions. Respondents: 1,361,027,168. Responses: 359,274,110. Estimated Total Burden Hours: 28,981,362. Estimated Total Costs: $262,270,078. Description:
  12. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
  13. PLR 199941023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsOct 15, 1999
    …mpany in exchange solely for Group stock and the assumption by Company of liabilities of Mutual (§§ 361(a) and 357(a)). (6) Mutual will recognize no gain or loss on the transfer of Group stock to Mutual Members in exchange for their Mutual Member Interests (§ 361(c)). (7) Mutual Members will recognize no gain or loss o…
  14. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997
    …e retirement savings on a tax-sheltered basis. See H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 361; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80, 210. Under the statutory framework thus established, individuals could obtain a limited deduction for amounts contributed to individual retirement accounts while earni…
  15. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  16. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … affected level-funded group health plans by participant count has been provided below in Table 21.[361] 3.2. TPAs and Issuers The Department also estimates that the proposed rule will indirectly affect 205 TPAs and 373 issuers in the group market with 809 issuers/State combinations.[362] These are service providers ac…
  17. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …i) to enforce any * * * terms of the plan.'" Sereboff v. Mid. Atl. Med. Servs., Inc., 547 U.S. 356, 361 (2006)(quoting 29 U.S.C. sec. 1132(a)(3)). The trustee may only obtain relief under section 1132(a)(2), howevèr, if the relief sought falls within "'those categories of relief that were typically available in equity'…
  18. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …sh method of accounting, MIT 84 claimed a net loss of $3,035,000. This was the excess of the $4,194,361 payroll costs over reported partnership income of $1,159,361. 18 On their individual income tax returns for 1984, the 21 investors in MIT 84 reported Schedule E partnership losses from MIT 84 in proportion to their i…
  19. 85 T.C. 869; 85 T.C. No. 51 — Griswold v. Commissioner
    IRCCourt RulingsNov 26, 1985
    … retirement savings on a tax-sheltered basis. See H. Rept. 93-807, at 126, 1974-3 C.B. (Supp.) 236, 361; S. Rept. 93-383, at 131, 1974-3 C.B. (Supp.) 80, 210. Under the statutory framework thus established, individuals could obtain a deduction for amounts contributed to individual retirement accounts, individual retire…
  20. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …7,641 170,000 62 2,435,384 74,170 45 1,322,938 56,472 45 1,007,267 175,000 62 2,507,012 76,352 45 1,361,876 58,133 45 1,036,893 - 13 - In determining the permissible normal retirement benefit under the plan