120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…end 1,599,938
320,420
392,944
425,604
c. Paid at yearend [a + b] 30,689,717 6,859,600 11,308,043 12,247,933
1
In 1991, this is the present value of active benefits only, excluding the 1991 net benefit costs.
2
In 1991, this includes the normal cost for active participants, plus the entire present value for
those retire…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsFeb 24, 2016
…ff'g in part, rev'g in part 11 T.C.M. (CCH) 274
(1952), and Shaara v. Commissioner, T.C. Memo. 1980-247. Both Lashells'
Estate and Shaara involved similar facts.¹7 The taxpayers received payments,
portions of which they were required to pay over as kickbacks.¹8 Although the
kickback agreements were unenforceable, the t…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…o types of State-level PBM disclosures: inter-firm disclosures [246]
and disclosures to regulators.[247]
IRCCourt RulingsJul 11, 2024
…rnzen v. United States , 875 F.2d 228,
229 (9th Cir. 1989) ; Reimels v. Commissioner, 123 T.C. 245, 247 (2004) ,
aff’d , 436 F.3d 344 (2d Cir. 2006) . Because of fiscal necessities, however ,
Congress has imposed income tax on these benefits for the last 40 years .
Ern zen , 875 F.2d at 229; Reimels, 123 T.C. at 247; s…
IRCCourt RulingsApr 26, 2005related by meaning
The legislative history of
section 7476 makes clear that Congress did not expect the Court
to conduct a trial de novo in declaratory judgment actions arising under that section, no matter whether that action arose
with respect to the initial qualification or the continuing
qualification of a retirement plan. See Tamko…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…s with less than 100 employees, of which 30,300 are self-insured [246] and 54,600 are fully funded.[247]
b. Participants and Enrollees
The Departments estimate that there are 35.6 million participants in ERISA-covered group health plans with also 100 employees, of which 5.6 million are in self-insured plans and 30.1 mi…
ERISACourt RulingsJan 20, 1998
…erest involved therein. Complainants assessed a civil penalty
against Respondents in the amount of $247,168.00 pursuant to
section 502(i) of ERISA and the regulations promulgated thereunder.
In its answer, Respondents challenged the assessment of the
penalties on various factual and legal grounds as discussed
below.
II…
IRCCourt RulingsFeb 28, 2024related by meaning
y Judgment Standard
The purpose of summary judgment is to expedite litigation and
avoid costly, unnecessary, and time-consuming trials. See Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). We may grant summary
judgment when there is no genuine dispute of material fact and a decision may be rendered as a matte…
IRCCourt RulingsDec 2, 2010
…v.
Commissioner, T.C. Memo. 1991-414 (citing Towers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957));
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
…5
SECTION 34. PAPERWORK REDUCTION ACT
245
DRAFTING INFORMATION
246
APPENDIX A SCHEDULE OF USER FEES
247 .01 Letter ruling requests
247
.02 Opinion letters on prototype individual retirement accounts and/or annuities, SEPs, SIMPLE IRAs, SIMPLE IRA Plans, Roth IRAs, and dual-purpose IRAs
247
.03 Opinion letters on master…
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…
79 FR 21127 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Apr 15, 2014
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 247, as set forth below, is added to the table.
Appendix B to Part 4022—Lump Sum Interest Rates For PBGC Payments
* * * * *
Rate set
For plans with a
valuation date
Immediate annuity rate
(percent)
Deferred annuities
(pe…
IRCCourt RulingsNov 4, 1998related by meaning
mulgated under the general
rulemaking power vested in the Secretary by section 7805(a).
Peterson Marital Trust v. Commissioner
, 102 T.C. 790, 797-798 (1994), (and cases cited therein), affd. 78 F.3d 795, 798 (2d
Cir. 1996). Section 1.7476-1(b), Income Tax Regs. (relating to
interested parties), has been promulgated un…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024
…8
246 .06 Opinion letters on pre-approved plans submitted pursuant to Rev. Proc. 2023-37 (§ 401(a))
247
.07 Advisory letters on § 403(b) VS plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28
247
.08 Determination letters
247
.09 User fees for VCP submissions under EPCRS Revenue Procedure 2021-30
247
APPENDIX B…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsDec 11, 1997related by meaning
o be
treated as an amount received as a loan on the date of such
renegotiation, extension, renewal, or revision. TEFRA, sec.
236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2)
if it (1) is in an amount not exceeding a prescribed ceiling that
in no event may be more than $50,000, …
IRCCourt RulingsOct 12, 1978related by meaning
rnal Revenue Service." Sec. 7476(b)(3). Section 7476(b)(4) requires that the plan or amendments thereto be put into effect before a petition is filed. Finally, section 7476(b)(5) states that if the Commissioner sends notice of his determination by registered or certified mail to an interested party, then no declaratory…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
IRCCourt RulingsMar 12, 2008
…00 238,112 20,049 258,16 1
8 258,161 25,000 233,161 19,653 252,81 4
9 252,814 25,000 227,814 19,225 247,03 9
10 247,039 25,000 222,039 18,763 240,80 2
11 240,802 25,000 215,802 18,264 234,06 6
12 234,066 25,000 209,066 17,725 226,79 1
13 226,791 25,000 201,791 17,143 218,93 5
14 218,935 25,000 193,935 16,515 210,44 9
1…