Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 6 T.C. 933 (not yet in the library — opens the official source)
82 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. PLR 200521012 — Special Rules for Pensions, Annuities, and Certain Other Deferred Income
    IRCPrivate Letter RulingsMay 27, 2005
    …rtment of the Treasury Washington, DC 20224 Number: 200521012 Release Date: 5/27/2005 Index Number: 933.00-00, 3405.00-00, 6041.00-00, 6041A.00-00, 6047.00-00 -------------------------- ------------------------------ ----------------------- - Third Party Communication: None Date of Communication: Not Applicable Person …
  2. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …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 retired as…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    .................................. 147 II. The 1986 amendment to section 482 ................... 166 JJ. The 1988 amendment to section 7805 regarding temporary regulations .......................................... 178 KK. The 1992 notice of proposed rulemaking ............. 178 8 LL. The 1993 temporary regulations an…
  4. T.C. Summary Opinion 2008-163 — Kenneth F. Reinert v. Commissioner
    IRCCourt RulingsDec 23, 2008
    …ponse , Northwestern sent petitioner a $1,269 .57 check representing the difference between the $29,933 . 78 cash value of the policy and petitioner ' s $28,664 .21 outstanding loan ( including interest accretions) against the cash value . Northwestern sent petitioner a Form 1099-R reflecting the above information and …
  5. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …4-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1991 $82,933 — $16,587 1992 45,233 — 9,047 1993 79,853 — 15,971 Marlton Group
  6. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    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…
  7. 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…
  8. T.C. Memo. 2012-215 — Harry Robert Haury v. Commissioner
    IRCCourt RulingsJul 30, 2012
    …million of development costs. In 2007, to ameliorate cashflow problems, petitioner transferred $434,9335 to the companies from his IRA (i.e., $120,000, $168,000, $100,000, and $46,933 on February 15, April 9, May 14, and July 6, respectively).6 In addition, petitioner executed interest-bearing promissory notes relating…
  9. T.C. Memo. 1997-70 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 10, 1997related by meaning
    Judicial Notice Motions. - 4 - Rule 201(f) of the Federal Rules of Evidence provides that judicial notice may be taken at any stage of the proceeding. Petitioner's Judicial Notice Motions will be denied in this case, however, because their many paragraphs constitute nothing more than a hodgepodge of argument and statem…
  10. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  11. 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…
  12. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  13. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    …and $3,674 paid by applying dividends to premiums. Before terminating the contract, he received $35,933.24 that was excludable from gross income: the $2,986.94 dividend payment in 2004; the $31,063.30 proceeds from the 2004 surrender of the paid-up additional insurance; and the $1,883 dividend payment in 2005. Hence hi…
  14. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  15. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019
    … words "solar", "fuel cell", "wind", or "geothermal". The IRS issued Notice 2009-41, 2009-19 I.R.B. 933, to provide interim guidance for the procedures that manufacturers could follow to certify property as - 45 -
  16. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998related by meaning
    titioner, WE 7, and - 18 - 4 The complaint filed in the Superior Court indicates that the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987. the Guardian Construction Co., Inc., as corporate partners of Estes Co. Petitioner was identified as a partner…
  17. Treas. Reg. § 1.401(a)(9)-6(m)(4)(i)(B) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    …ortalityrate duringyear Discountedadditionalbenefitswithin year 2028 2029 1.00000 .97590 5.03321 12,933 2030 .96679 6.92943 .03739 7 12,398 2031 8.93064 .88517 .04198 11,756 2032 .89157 .84302 .04715 11,055 2033 .84953 .80288 .05305 10,310 2034 .80446 .76464 .05979 9,526 $67,978 5 One-quarter age 78 rate plus three-qua…
  18. PBGCPBGC Opinion LettersSep 28, 1994
    …pect to t hat plan when t hey a re due ." n1 n1 Sectio n 40 07 o f ER ISA was am end ed b y section 933 1(c) of the O mnib us B udge t Rec onc ili ati on Act of 1987 ("OBRA"), Pub. L. 100- 203, 101 Stat. 1330, 1330-368 (1987). The eff ecti ve date was establish ed b y section 933 1(f) of O BR A, 10 1 Sta t. 133 0, 13 3…
  19. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    … Total $1,789,886 $7,232,234 $7,528,108 $76,028 $19,333 $59,932 Per-Entity $961 $911 $911 $1,077 $1,933 $1,933 Retrospective Review: Total $350,946 $1,351,008 $1,406,278 $13,309 $4,661 $14,449 Per-Entity $188 $170 $170 $189 $466 $466 Total: Total $5,178,174 $36,690,135 $38,191,149 $175,871 $503,542 $150,125 Per-Entity …
  20. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…