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70 documents · 0.57sAllIRCERISAPBGCJoint Board
  1. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    could pass legislation making the new unlimited marital deduction applicable to pre-ERTA instruments containing maximum marital deduction formulas. 1 *139 The trust in issue provides that the amount to be placed into Trust A is "The Marital Deduction Amount consisting of that amount of the balance of the Trust Estate …
  2. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …087 entities × 2 hours) × $159.34 = $1,621,125. Back to Citation 634.  The burden is estimated as: [177 financial institutions + (3,960 independent producers × 5%)] × (10 minutes ÷ 60 minutes) = 63 hours. A labor rate of approximately $159.34 is used for a legal professional. The labor rate is applied in the following …
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    ement of this title, including all rules and regul ations as may be necessary by reason of any alteration of law in relation to internal revenue.” 108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat. at 917, was the provision in the Internal Revenue Code of 1954 that was analogous to section 3791(b) of t…
  4. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …ISA fiduciary will implicate difficult tradeoffs.” Hughes v. Northwestern University, 595 U.S. 170, 177 (2022). And, as discussed above, a fiduciary must act based on “the circumstances as they reasonably appear to [the fiduciary] at the time when he does act and not at some subsequent time when his conduct is called i…
  5. 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…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …ntends that the corporation is liable for section 6651(a)(2) failure to pay additions to tax of $11,177.73 and $22,326.43 for the 2003 and 2004 tax years, respectively, because the corporation did not pay the excise tax due to be
  7. Court of Appeals for the Eleventh Circuit — Ann Johnson v. Russell Investments Trust Company
    ERISACourt RulingsAug 17, 2026
    …“Russell’s strength is their expertise in providing consulting services and investment advice.” Doc 177- 29 at 5. Upon reviewing the memo, the RFP Team selected Russell as one of its four finalists because of its “ [ s ] trong expertise in providing consulting service and investment advice .” Doc. 177-30 at 4. But i n …
  8. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …erical workers prepare and distribute comparative analyses upon participant request 2,129,516 0.083 177,460 65.99 11,710,585 2.79 2,477,543 Clerical workers maintain recordkeeping 2,129,516 0.083 177,460 65.99 11,710,585 0 0 Total 2,129,536 355,020 23,433,073 2,477,543 1.5. Overall Summary
  9. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    … the time of conversion, the Cgroup term policy’s conversion credit balance was $84,397.58, and $80,177.70 of that amount ($84,397.58 x 95%) was transferred to the C-group conversion UL policy for potential earning. Dr. Desai will earn these credits in 120 equal monthly installments, beginning October 1996. The convers…
  10. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
  11. 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
    … Matters 176 SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES? 177 .01 Pre-approved plans 177 .02 Employee Plans Compliance Resolution System 177 .03 Chief Counsel 177 .04 Determination letters not issued for requests for minimum funding waivers 177
  12. 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
    …Right to status conference 176 .17 How to request status conference 176 .18 Correct format required 177 SECTION 11.WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 177 .01 Requesting determination letters 177 .02 Elimination of remedial amendment cycle for individually designed …
  13. 85 FR 31714 — Income Tax Withholding on Certain Periodic Retirement and Annuity Payments Under Section 3405(a)
    IRCProposed Rules (FR)Proposed May 27, 2020related by meaning
    in the Background section of the preamble, certain provisions of § 35.3405-1T reflect the rule under section 3405(a)(4) prior to amendment by TCJA.[3] Specifically, Q&As a-10, b-3, and b-4 of § 35.3405-1T each provide that the default rate of withholding on periodic payments is determined by treating the payee as marri…
  14. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    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…
  15. 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
    …FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 177 .01 In general 177 .02 Certain information required in requests for letter rulings or determination letters, as applicable 177 .03 Additional information required in certain circumstances 186 .04 Address to send the …
  16. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    … Date of report 03/11/91 03/11/91 07/10/91 01/20/93 1992 1992 1993 1993 1994 Fund value at yearend $177,095 $177,095 $184,012 $176,364 $148,625 Policy values 177,103 177,103 186,612 178,964 177,545 Surrender value 157,104 157,104 166,613 161,097 162,772 Addit. contr. available 202,263 197,155 248,761 243,663 296,318 Da…
  17. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    itioner and his wife owned 100 percent of the Garrahan Agency, and since petitioner is a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G). 3. Conclusion The Garrahan Agency is a disqualified person under section 4975(e)(2), and thus it and petitio…
  18. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …, An Arizona Professional Corporation, docket No. 19117-90; and Brody Enterprises, Inc., docket No. 177-91. * This opinion supplements our previously filed opinion in Citrus Valley Estates, Inc. v. Commissioner , 99 T.C. 379 (1992), affd. in part and remanded in part 49 F.3d 1410 (9th Cir. 1995). 106 T.C. No. 23 UNITED…
  19. 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…
  20. 88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    ent distribution channel is estimated as: (215 insurance companies−38 large insurance companies) = 177 small insurance companies. Back to Citation 65.  This is estimated as: [(177 small insurance companies × 5 hours) + (38 large insurance companies × 10 hours)] = 1,265 hours. A labor rate of $159.34 is used for a legal…