IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
IRCCourt RulingsMar 3, 2016
… to the IRS, the income
was not included on the income tax return: a Form 1099-R reporting the $109,154
IRA distribution from RBS Citizens Bank; a Form 1099-INT, Interest Income,
reporting interest income of $13 from EMC Mortgage Corp.; a Form 1099-DIV,
Dividends and Distributions, reporting taxable dividend income of …
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
IRCCourt RulingsJan 14, 2013★ strong match
…5 13,000 $12,923
1986 15,521 18,764
1987 26,769 29,077
1988 36,000 36,000
1989 36,000 36,000
1990 4,154 4,154
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…atements
Pre-Statute
96.1
3.9
0.0
$0
$0
$0
$0
$0
1
51.3
48.7
44.8
53,502,795 18,284,236
4,949,140
5,154,737
81,890,909
2
57.3
42.7
38.8
0
0
0
4,471,532
4,471,532
3
60.2
39.8
35.9
0
0
0
4,139,119
4,139,119
4
61.7
38.3
34.4
0
0
0
3,977,383
3,977,383
5
62.3
37.7
33.8
0
0
0
3,898,691
3,898,691
6
62.7
37.3
33.4
0
0
0
3,860,…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
… additional performance metrics for private funds—such as:
(1) the public market equivalent (PME); [154]
(2) the modified IRR (MIRR) which adjusts for timing of investment flows;
(3) the multiple on invested capital (MOIC) which measures the total value returned to investor relative to the total capital invested; [155]…
IRCCourt RulingsMar 10, 2020★ strong match
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ir health-care budgets, with the median share rising from 21 percent in 2021 to 27 percent in 2023.[154]
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
… PROCEDURE?
152
.01 In general
152
.02 Specific changes
153
PART I. GENERALLY APPLICABLE PROCEDURES
154
>SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS?
154
.01 In general
154
.02 Letter ruling
154
.03 Closing agreement
154
.04 Determination letter
154
.05 Opinion letter
155
.06 Ora…
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
Rev. Proc. 2020–4
TABLE OF CONTENTS
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE?
154
.01 Purpose of revenue procedure
154
.02 Organization of revenue procedure
154
.03 Other guidance affecting this revenue procedure
154
.04 Updated annually
157
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 20…
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…
IRCCourt RulingsAug 18, 2015
…l years previously. Between 2003
and 2006 petitioners made additional after-tax investments of $346,154 in the
Allstate annuity contract.
In March 2007 petitioners surrendered the Allstate annuity and transferred
the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of the Al…
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
… revenue procedure
152
.03 Other guidance affecting this revenue procedure
152
.04 Updated annually
154
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4?
154
.01 In general
154
.02 Changes made to Revenue Procedure 2018–4
154
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PR…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsDec 19, 1995
…ner's contributions in the amount of
- 6 - $18,112.25, and the taxable amount as the difference or
$154,446.89.
On their Federal income tax return for 1989, petitioners
disclosed the receipt of the Transfer Refund. Specifically, on
line 17a of Form 1040, petitioners entered $154,447 as the amount
of "Total pensions and…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
IRCCourt RulingsJul 14, 2005★ strong match
…lements our prior
Opinion in Transp. Labor Contract/Leasing, Inc. & Subs. v.
Commissioner, 123 T.C. 154 (2004).
SERVED JUL 1 4 2005
- 2 -
motion for reconsideration of the Court's Opinion in this case
(petitioner's motion for reconsideration) set forth in 123 T.C.
154 (2004) (Transport Labor I) and petitioner's motion …
IRCCourt RulingsSep 14, 2016
… tax deficiency of $15,949 stemmed from the IRS's
determination that Perry had received a total of $154,255 of taxable retirement
income in 2011 but had reported only $97,313. The $154,255 amount was
composed of $96,000 from Freedom Credit Union and $58,255 from PSERS. The
difference between the proposed amount of taxa…
IRCCourt RulingsMay 3, 1995
Cumulative Difference
-0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji
1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3
Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…