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89 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ecure , supervisory approval for “the initial determination of such assessment.” See § 6751(b)(1). On October 19, 2020, r espondent filed an Answer to the Amended Petition , denying petitioner’s allegation and urging that section 6751(b) “ does not apply to . . . [section] 4973.” On November 1, 2023, respondent filed t…
  2. 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…
  3. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    ders 1 $181.06 3,552 $643,125 Notice Preparation (In-House) 67,580 = 675,798 Small Plans × 10% Not Using a Service Provider 1 181.06 67,580 12,236,003 Adding Contact and Plan Information to Drafted Notices 608,218 = 675,798 Small Plans × 90% Using a Service Provider 5/60 70.29 50,685 3,562,639 Total 121,817 16,441,768 …
  4. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …$9,054. § 1903.15(d)(1) 124,709 126,749. § 1903.15(d)(2) 124,709 126,749. § 1903.15(d)(3) 12,471 12,675. § 1903.15(d)(4) 12,471 12,675. § 1903.15(d)(5) 12,471 12,675. § 1903.15(d)(6) 12,471 12,675. ( printed page 5383) Department of Labor Employee Benefits Security Administration Title 29—Labor PART 2575—ADJUSTMENT OF …
  5. Treas. Reg. § 1.401(l)-3(f)(3) — Permitted disparity for defined benefit plans.
    IRCRegulationsMay 18, 2016
    …ple 6 except that the plan reduces the gross benefit percentage for early retirement at age 55 to 1.675 percent. Because the gross benefit percentage is reduced by 0.325 percent (from 2.0 percent to 1.675 percent), the same percentage point reduction made in the offset percentage (from 0.65 percent to 0.325 percent), t…
  6. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …00 2/15/87 4,000.00 2/15/88 10,000.00 8/15/88 5,000.00 1/31/90 6,000.00 4/16/90 18,000.00 1/01/91 1,675.86 - 4 - Date Amount 5/22/91 2,151.47 3/24/92 2,500.00 6/17/92 5,000.00 Each loan is evidenced by a written note, and the terms of the notes are set forth on substantially identical forms. Each note requires repaymen…
  7. Treas. Reg. § 1.422-5(e) — Permissible provisions.
    IRCRegulationsSep 9, 2016
    …at $0 per share plus 15 shares at $25 per share)). In addition, A must recognize a capital gain of $675, which consists of $375 ($450, the amount realized from the sale of 15 shares, less A's basis of $75) plus $300 ($1,800, the amount realized from the sale of 60 shares, less A's basis of $1,500 resulting from the inc…
  8. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  9. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …er requirements of 26 C.F.R. sec. 1.482-1(h)(2) (2006). See Ramm v. Commissioner , 72 T.C. 671, 674-675 (1979) ( finding it unnecessary for the Court to evaluate the validity of a requirement imposed by a regulation if the taxpayer did not satisfy the other requirements imposed by the regulation). G. C ircumvention or …
  10. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017
    …n, for 2011 (2011 return). On the 2011 return petitioner reported taxable IRA distributions of $119,675,4 interest of $136 (including $5 of tax-exempt interest), a net business loss from a sole proprietorship of $39,379, and 2The Forms 1099-R that were included with petitioner's 2011 return as a stipulated exhibit do n…
  11. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … (hours) Total annual burden (hours) Total estimated labor cost Total estimated cost 2022 22,257 36,675 1.7981697 65,948 $6,464,751 $191,734 ( printed page 56086) 2023 22,257 36,675 1.7981697 65,948 6,464,751 185,452 2024 22,257 36,675 1.7981697 65,948 6,464,751 185,452 3 Year Average 22,257 36,675 1.7981697 65,948 6,4…
  12. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  13. Treas. Reg. § 1.401-3(a)(3) — Requirements as to coverage.
    IRCRegulationsMar 14, 2019
    …igible to participate because of age requirements 150 (iii) Total employees eligible to participate 675 (iv) Percentage of employees in item (i) eligible to participate 81 + % (v) Minimum number of participating employees to qualify the plan (80 percent of 675) 540 If only 70 percent, or 578, of the 825 employees satis…
  14. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  15. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …health insurance with offer of fertility coverage in group plan × 16.6 percent offer rate) = 26,174,675 participants aged 25 to 45 enrolled in non-federal, employer-sponsored health insurance offered excepted fertility benefits coverage. Back to Citation 152.  National Center for Health Statistics, National Survey of F…
  16. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  17. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  18. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  19. 29 C.F.R. § 2530.200b-3(f)(4)(iii) — Determination of service to be credited to employees.
    ERISARegulationsJan 1, 2017
    …s of a vesting computation period an hourly employee is paid at a rate of $3.00 per hour and earns $675 for the performance of duties; during the next 6 months, the employee is paid at a rate of $3.50 per hour and earns $1,575 for the performance of duties; during the final 3 months the employee is paid at a rate of $3…
  20. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…