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88 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. IRCCourt RulingsAug 3, 1979related by meaning
    to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption. II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
  2. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …,071 Other violations of statutes, regulations or employer assurances 21-214 214-428 428-1,071 PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 17. The authority citation for subpart G of part 570 continues to read as follows: Authority: 52 Stat. 1060-1069, as amended; 29 U.S.C. 201-219; 28 U.S…
  3. 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…
  4. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …GULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 20. The authority citation for Subpart G of part 570 continues to read as follows: Authority: 52 Stat. 1060-1069, as amended; 29 U.S.C. 201-219; 28 U.S.C. 2461 note (Federal Civil Penalties Inflation Adjustment Act of 1990); Pub. L. 114-74 at § 701. § 570.140 [Amended]…
  5. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012
    …d also determined, consistent with the IRM, that Ms. Taylor's section 401(k) account balance of $38,570 was reachable by levy because petitioners did not need that inëome to provide for necessary living expenses. See IRM pt. 5.15.1.23 (May 9, 200%) (funds held in a retirement account are reachable by levy when the taxp…
  6. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    … of statutes, regulations or employer assurances 20-201 201-402 402-1,005 ( printed page 5382) PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 15. The authority citation for Subpart G of part 570 continues to read as follows: Authority: 52 Stat. 1060-1069, as amended; 29 U.S.C. 201-219; 28 U.S…
  7. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998★ strong match
    ontrol of the use of the IRA distributions. We are not persuaded by respondent's argument that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the forfeiture, and his avoidance of a fine or potentially longer prison sentence, petitioner should be treated …
  8. 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…
  9. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    … are strictly construed in favor of the Government.” (quoting Lucia v. United States, 474 F.2d 565, 570 ( 5th Cir. 1973))); Tice v. Commissioner, No. 24983- 15, 160 T.C., slip op. at 4 (Apr. 10, 2023) (“In effect, a period of limitations runs against the collection of taxes only because the Government, through Congress…
  10. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  11. 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…
  12. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    … items on the Form 1040 are relevant in this case. First,.petitioner claimed a business loss of $19,570 that was due to Xclueseif. On the attached Schedule C petitioner reported gross receipts of $1,500 and total expenses of $21,070, leading to the $19,570 loss. Petitioner listed the gross receipts and expenses from Xc…
  13. 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…
  14. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    …96-989 Other violations of statutes, regulations or employer assurances 20-198 198-396 396-989 PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 23. The authority citation for Subpart G of part 570 is revised to read as follows: Authority: 52 Stat. 1060-1069, as amended; 29 U.S.C. 201-219; 28 U.…
  15. 89 FR 23090 — Amendment to Prohibited Transaction Class Exemption 84-14 for Transactions Determined by Independent Qualified Professional Asset Managers (the QPAM Exemption)
    ERISAFinal Rules (FR)Apr 3, 2024
    …ured by the Federal Deposit Insurance Corporation, with equity capital or net worth in excess of $1,570,300 as of the last day of the fiscal year ending no later than December 31, 2024, $2,140,600 effective as of the last day of the fiscal year ending no later than December 31, 2027, and $2,720,000 effective as of the …
  16. 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…
  17. 77 T.C. 477 — Chapman v. Commissioner
    IRCCourt RulingsAug 24, 1981related by meaning
    in 1976 within the meaning of the statutory limitation and, hence, is not entitled to a deduction under section 219 for the payment to an IRA in 1976. Section 4973 imposes an excise tax of 6 percent on "excess contributions” made to án IRA during the taxable year. Since petitioner is not entitled to a deduction under s…
  18. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  19. Treas. Reg. § 1.72-7(b)(4) — Adjustment in investment where a contract contains a refund feature.
    IRCRegulationsJul 26, 2016
    …ed) $10,000 Pre-July 1986 portion of the amount to be received annually ($10,000/$21,053 × $1,200) $570.00 Number of years for which payment guaranteed ($10,000 ÷ $570) 17.50 Rounded to nearest whole number of years 18 Percentage in Table III for age 65 and 18 years (percent) 30 Subtract value of the refund feature to …
  20. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…