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92 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …to as designated Roth matching contributions and designated Roth nonelective contributions. Section 604(d) of the SECURE 2.0 Act adds section 402A(f)(3) of the Code, which defines “matching contribution” for purposes of section 402A to mean any matching contribution described in section 401(m)(4)(A), and any contributi…
  2. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    … Number of responses Burden hours per respondent Total burden hours Total cost 1,959 23,508 156 305,604 $28,793,069 The Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,527,110 hours and an equivalent associated cost of approximately $230,686,747 to develop and build th…
  3. 89 FR 64538 — Quality Control Standards for Automated Valuation Models
    IRCFinal Rules (FR)Aug 7, 2024
    …nd are also addressed in those parts. The FRFA for this rulemaking follows this discussion. Section 604(a) of the RFA sets forth the required elements of the FRFA. Section 604(a)(1) requires the FRFA to contain a statement of the need for, and objectives of, the rule. Section 604(a)(2) requires the FRFA to contain a st…
  4. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  5. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    luded that the bulk of the $26 million received by hi s IRA was attributable to his relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…
  6. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … and Value Before Fees, Nat'l Inst. of Pension Adm'rs, Apr. 11, 2016); Cunningham v. Cornell Univ., 604 U.S. 693, 711 (2025) (Alito, J. concurring) (citing CHUBB, Excessive Litigation Over Excessive Plan Fees in 2023 (Apr. 2023)). Back to Citation 31.
  7. 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…
  8. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty. OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
  9. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  10. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …,906 Per-Entity 80 80 80 80 345 345 345 Retrospective Review: Total 6,043 562,032 12,087 Per-Entity 604 604 604 ( printed page 75971) Total: Total 20,078,016 81,756,286 90,848,839 1,660,214 119,169 11,082,746 238,339 Per-Entity 696 696 696 749 1,671 1,671 1,671 SBA: Threshold (in millions)
  11. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    petitioner sought to deduct, as the sole shareholder, the entire net operating loss of $16,946.11 for the initial short taxable year on his Form 1040. We held in Bianchi that the contribution, including the compensation paid to petitioner during the initial 7-day taxable year, was unreasonable and properly disallowed, …
  12. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010★ strong match
    .a distribution of $6,277 from a qualified retirement . plan during~the'2001 tax year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that she qualified for any of the . exceptions in section 72(t)(2) . Accordingly ; we hold that Ms .-O'Boyle…
  13. Treas. Reg. § 1.417(e)-1(d)(6)(ii)(D) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …at age 65 is 10.432, and the present value factor for a temporary annuity payable until age 65 is 4.604. The present value of the benefit payable to Participant R under the Social Security level income option is $225,901 ($1,945.80 × 4.604 × 12 + $945.80 × 10.432 × 12). Because this present value is less than the minim…
  14. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  15. 89 FR 43675 — Prohibited Transaction Exemption 2006-06 for Services Provided in Connection With the Termination of Abandoned Individual Account Plans
    ERISAFinal Rules (FR)May 17, 2024related by meaning
    section 4975(c)(2) necessitate proposing an amendment to the exemption. Back to Citation 26.   See 29 CFR 2578.1(d)(2)(v). Back to Citation 27.   See Section I(a)(3) of this exemption amendment. Back to Citation 28.   See paragraph 29 CFR 2578.1(c)(3) of the QTA Regulation or in the case of a QTA described in Section …
  16. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968related by meaning
    -10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
  17. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
  18. Notice 2024-82 — This notice sets forth the 2024 Required Amendments List (2024 RA List). The 2024 RA List applies to individually designed plans qualified under section 401(a)…
    IRCNoticesDec 23, 2024
    …reatment of employer contributions or nonelective contributions as Roth contributions under section 604 of the SECURE 2.0 Act are included in Part C. This placement is because plans are not required to include terms providing for that Roth treatment (so that section 604 of the SECURE 2.0 Act will not be listed on any R…
  19. 90 FR 44527 — Catch-Up Contributions
    IRCFinal Rules (FR)Sep 16, 2025
    …ntributions “made on the employee's behalf” under a plan was added to section 402A(b)(1) by section 604(b) of ( printed page 44532) the SECURE 2.0 Act. Section 604 of the SECURE 2.0 Act permits certain nonelective contributions and matching contributions that are made after December 29, 2022, to be designated Roth cont…
  20. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020related by meaning
    e Schedule C1 for BJW rather than the Schedule C2 for GSE. We expect the parties to treat the deduction as BJW's in the Rule 155 (continued...) - 31 - [*31] ix. Car and Truck For the reasons explained supra part II(A)(2)(iii), we hold that petitioners failed to substantiate GSE's reported car and truck expenses. We the…