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82 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999★ strong match
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  2. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    …n and not as findings of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this case would apparently lie to the U.S. Court of Appeals for th…
  4. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    … two surveys' findings as a basis, the Department assumes the meeting frequency factors in Table 6.[199]
  5. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …than doubled from 2011 to 2013, indicating a substantial increase after the final rule took effect.[199]
  6. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ed guidance 198 .05 Issues in prior return 198 .06 Generally not to business associations or groups 199 .07 Generally not to foreign governments 199 .08 Generally not on federal tax consequences of proposed legislation 199 SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE THE DISCRETI…
  7. 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…
  8. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024
    …1-1(a)(1) and (2) as to who is the owner of a qualified film or television production. (42) Section 199.—Income Attributable to Domestic Production Activities.—The determination under § 1.199-3(f)(1) as to who is the taxpayer that has the benefits and burdens of ownership under Federal income tax principles of any qual…
  9. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    …e are not presented with a sec. 72(t) issue. See Shimota v. United States, 21 Cl. Ct. 510, 525-526 (1990), on appeal (Fed. Cir., Nov. 1, 1990). The Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388, while maintaining this option for a severely limited class of eligible individuals, suspended it…
  10. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
  11. 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
    …e a copy of plan and amendments 198 .04 Restatements required 198 .05 Section 414(x) combined plans 199 SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION? 199 .01 Eligibility to apply for a determination letter for a Cycle 3 qualified pre-…
  12. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  13. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    …03 Determination letter applications on Form 5300 196 .04 Scope of review 198 .05 Submission period 199 .06 Reliance equivalent to determination letter 199 SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR FORM 5307? 199 .01 Scope 199 .02 Form 5307 filing procedures 199 .03 Additional information with…
  14. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …er Strategies is entitled to business expense deductions for meals and entertainment expenses of $2,199 and $4,739 for 2004 and 2005, respectively, and travel expenses of $53,707 for 2005; (4) whether petitioner is liable for additions to tax under section 6651(a)(1) for failure to file Forms 5329, Additional Taxes on …
  15. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …f subsequent publication of revenue ruling, etc. 198 .04 Effect of subsequent amendment by employer 199 .05 Revocation or modification of a determination letter 199 .06 Determination letter revoked or modified based on material change in facts applied retroactively 199 .07 Not otherwise generally revoked or modified re…
  16. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    …uishable from the present one. In view of the foregoing, we hold that petitioner is not taxable, in 1990, on the net wages withheld by the school district during that year. Because 1990 is the only year before us, we need not, and do not, decide whether the net wages are taxable in some other year. Issue (2): Section 7…
  17. 75 FR 19542 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Apr 15, 2010
    …) On or after Before i1 i2 i3 n1 n2   *         *         *         *         *         *         * 199 5-1-10 6-1-10 3.00 4.00 4.00 4.00 7 8 3. In appendix C to part 4022, Rate Set 199, as set forth below, is added to the table. APPENDIX C TO PART 4022—LUMP SUM INTEREST RATES FOR PRIVATE-SECTOR PAYMENTS * * * * * ( pr…
  18. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    …er is liable for the 10-percent additional tax on premature distributions from a qualified plan for 1992 as provided in section 72(t). To reflect the above, Decision will be entered under Rule 155 .
  19. 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
    …hority must be distinguished 198 .10 Employer-employee relationship 198 .11 Incomplete applications 199 .12 Effect of failure to disclose material fact 199 .13 Where to file requests 199 .14 Submission of related plans 200 .15 Withdrawal of requests 200 .16 Right to status conference 200 .17 How to request status confe…
  20. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980related by meaning
    . Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…