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86 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …sufficient market data for comparable properties. See Whitehouse Hotel Ltd. P’ship v. Commissioner, 139 T.C. 304 , 324 – 25 (2012) (holding that other valuation methods are “not favored if comparable- sales data are
  2. 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…
  3. PBGCRegulationsJan 1, 2017★ strong match
    [Reserved]
  4. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
  5. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …g cost if using permitted practices   (A) (B) (C) (D) (E) (F) (G) (H) (I) Providers: PP 1,988 8,020 139,973,458 3,499,336 233,289 $409,291,139 $25,751,617 $435,042,756 Providers: Non-PP 1,988 8,020 8,303,510 830,351 27,678 97,119,931 3,055,277 100,175,208 100,175,208 Total 1,988 148,276,968 4,329,687 260,967 506,411,07…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  7. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  8. PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsSep 25, 2009
    …has as its basic function the systematic liquidation of the principal.” Se e also Comm’r v. Meyer , 139 F.2d 256 (6th Cir. 1943). Similarly, in Rev. Rul. 75-255, 1975-2 C.B. 22, the Service observed
  9. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …g future revenue.” Excelsior Aggregates, T.C. Memo. 2024-60, at *43 – 44 (citing Whitehouse Hotel , 139 T.C. at 325 ( observing that the income approach “has been judged an unsatisfactory valuation method for property that does not have a track record of earnings”)); see also J L Mins. , T.C. Memo. 2024-93, at *61 . Th…
  10. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …ith 50 participants Plans with 75 participants Plans with 100 participants Plan Premiums by Size * $139,440 $348,600 $697,200 $1,045,800 $1,394,400 Cost per Plan $2.30 $5.30 $10.30 $15.30 $20.30 Total 0.0016% 0.0015% 0.0015% 0.0015% 0.0015% * Plan Premiums are obtained by average annual premiums per covered participant…
  11. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    … 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 3,860,403 3,860,403 7 62.8 37.2 33.3 0 0 0 3,841,774 3,841,774 8 62.9 37.1 33.2 0 0 0 3,832,7…
  12. Notice 2025-60 — This notice sets forth the 2025 Required Amendments List (2025 RA List). The 2025 RA List applies to individually designed plans qualified under section 401(a)…
    IRCNoticesDec 22, 2025
    … transition rule for dividends (the “transition rule”) in section 70354(c)(2) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act. The transition rule modifies the application of section 951(a)(2)(B) of the Internal Revenue Code for certain taxable years of foreign corp…
  13. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  14. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996★ strong match
    rary purpose has been shown here. Because we are satisfied that our analysis of section 4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A. - 11…
  15. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …Issuers 811 Group Health Plans and Sponsoring Employers 522,811 Participants and Eligible Employees 139 54,411,264 Participants and Eligible Employees Likely to Enroll 743,361 The Departments seek comments on the number of entities that would be affected by these proposed rules. In particular, the Departments seek comm…
  16. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …stimates that the cost burden for preparing and mailing the notices will be approximately equal to $139, that is, 205 * ((2 * $0.05) + $0.58) = $139 (rounded). Therefore, the total cost associated with this requirement is (4 * legal professional labor rate of $140.96) + (7 * clerical labor rate of $55.23) + $139 = $1,0…
  17. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  18. 81 FR 47496 — Annual Reporting and Disclosure
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    5 or Fewer 0.088 0.091 178,694 6-10 0.084 0.087 105,458 11-25 0.067 0.070 139,971 26-50 0.040 0.041 86,936 51-75 0.022 0.023 38,822 76-90 0.018 0.018 14,491 90-99 0.016 0.016 6,341 Defined Benefit Pension—Not Eligible for 5500-SF: 5 or Fewer 0.002 0.003 566 6-10 0.050 0.086 82 11-25 0.041 0.069 60 26-50 0.016 0.027 40…
  19. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …djusting menus prior to the 2015 ruling, cautioning that the analysis may underestimate the effect.[139]
  20. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…