IRCCourt RulingsJan 26, 2006
…ection
7491(a)(2). Therefore, the burden of proof remains with
petitioner.
II. Distributions of $15,322.69 and $7,000
A. General
Section 408(d)(1) provides that any amount paid or
distributed from a qualified retirement plan generally must be
included in gross income by the distributee in the manner
provided under sect…
IRCRegulationsSep 17, 2024
…the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on January 1, 2006, of the loan it repl…
IRCCourt RulingsJul 31, 2000
…e end of that year, the
conversion credit balance was $7,485.21 ($4,865.74 + $2,962.50 -
$665.36 + $322.33); the $322.33 is the interest of 4.5 percent
earned on the conversion credit balance (($7,485.21 - $322.33) x
4.5% = $322.33)). Of the conversion credit balance, $6,755.40
could have been transferred at this time …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…ations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total
138,322
$18,646,718
Table 8—Cost for Distribution of New Paper Benefit Statements for 2020 Safe Harbor
[Year 1]
Description
Affected entities
Pages per
disclosure
Material costs per
page
Distribution
costs per
disclosure
Tot…
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…
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…
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…
IRCCourt RulingsAug 3, 1979related by meaning
155.
Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77.
Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue.
Respondent concedes …
IRCCourt RulingsApr 22, 2003related by meaning
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
… hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Insurance Sales Agent
250,000
$41,322,500
250,000
$41,322,500
Total
250,000
41,322,500
250,000
41,322,500
1.3.1.5 Mailing Cost for Disclosures Sent From Independent Producers to Retirement Investors
As discussed at the beginning of the cost section, the …
IRCCourt RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
85 FR 42706 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Jul 15, 2020
…S
1. The authority citation for part 4022 continues to read as follows:
Authority:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, rate set 322 is added at the end of the table to read as follows:
Appendix B to Part 4022 — Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set…
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…
IRCCourt RulingsJan 30, 2007
…ll Lynch, to protect
Taxable income
Cash Pay 123,000 Merrill Lynch,
to protect
Taxable income
Other 322,962 Merrill Lynch,
to protect
Taxable income
Total 1,118,870
Petitioners reported taxable income of $213,977, tax of $60,080,
tax on IRAs and other retirement plans of $63,717, and total tax
4(...continued)
2000.
- 1…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…f affected entities in section IV.C.
Back to Citation
278.
The burden is estimated as follows: 149,322 plans × 4 hours = 597,288 hours. A labor rate of $153.21 is used for a legal professional. The cost is estimated as follows: 149,322 plans × 4 hours × $153.21 = $91,510,494.
Back to Citation
279.
The per-plan burden…
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…
ERISACourt RulingsAug 10, 2026
… for appropriate remedies, sanctions, and ready access to the Federal
courts.’ ” Marks v. Watters , 322 F.3d 316, 322 (4th Cir. 2003) (quoting 29
U.S.C. § 1001(b) ).
USCA4 Appeal: 25-1350 Doc: 89 Filed: 08/10/2026 Pg: 3 of 21
4
As to Kelly’s third claim, h e allege d that, despite his request, the p lan administrator
r…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…