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93 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    …ting statement) as follows: Payor Classification Amount Merrill Lynch Short-term capital gain 1 $27,573 Bank of New York Short-term capital gain 1 2,802 First Investors Tax Interest 259 Exempt Fund Sovran Bank, NA Interest 138 Commonwealth Savings Interest 5 & Loan Merrill Lynch Dividends 540 Raytheon Co. Dividends 8 N…
  2. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …011, cannot exceed the total present value of the excess contribution adjusted for interest of $58, 573 ($15,300 plus $43,273).(vi) The funding standard carryover balance as of January 1, 2011, is $10,200, determined as the 2010 funding standard carryover balance less the $15,000 used to offset the 2010 minimum require…
  3. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …aries often find themselves “between a rock and a hard place,” Fifth Third Bancorp v. Dudenhoeffer, 573 U.S. 409, 424 (2014), or on a “razor's edge,” Armstrong v. LaSalle Bank Nat'l Ass'n,
  4. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    …ogy Associates, P .A . v . Commissioner , supra at 85-86 ; Booth v . Commissioner , 108 T .C . 524, 573 (1997) . The Court has broad discretion to evaluate the cogency of an expert's analysis . See Neonatology Associates, P .A . v . Commissioner , supra at 85 . Sometimes, an expert will help us decide a case . See, e .…
  5. 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…
  6. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    …lows: Penalty Year Deficiency sec. 6662(a) 2000 $347,369 $69,473 2001 341,566 68,313 2002 2,867,433 573,487 2003 12,869,823 2,573,965 2004 3,731,802 746,360
  7. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …isites of Rule 23 have been satisfied.” Schroeder v. Progressive Paloverde Ins. Co. , 146 F.4th 567, 573 (7th Cir. 2025) (citation modified). We review a district court’s decision to certify a case for
  8. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  9. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  10. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
  11. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    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…
  12. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  13. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    IRCCourt RulingsJan 16, 2020related by meaning
    bed in section 72(t) in respect of Mr. Merrell's IRA distribution is sustained. As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case. We have considered similar claims in the past and have observed that there is no -8au…
  14. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …r rule review + $88,115,522 for general disclosures + $50,935,672 for policies and procedures + $44,573,147 for the retrospective review + $413,225 for self-correction + $28,683,939 for recordkeeping) = $288,737,197. The total cost in subsequent years includes: ($43,710,694 for disclosures + $49,858,818 for policies an…
  15. 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…
  16. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    … table. Table 1—Affected Accounts   Baseline Post-rule Defined Contribution Plan Account Holders 86,573,634 86,573,634 × Job Separation Rate Associated with Modest Account Balances 20% 20% = Annual Account Churn 17,314,727 17,314,727 × Proportion with Balance of $7,000 or less 33% 33% = Affected Accounts 5,713,860 5,71…
  17. 88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Feb 2, 2023
    …eligious Exemption final rules). Back to Citation 7.   Wheaton College v. Burwell, 134 S. Ct. 2806, 573 U.S. 958, 189 L. Ed. 2d 856 (2014). Back to Citation 8.   Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751, 573 U.S. 682, 189 L. Ed. 2d 675 (2014). Back to Citation 9.   Zubik v. Burwell, 136 S. Ct. 1557 (2016). …
  18. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  19. 86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
    ERISAProposed Rules (FR)Proposed Oct 14, 2021
    …792 17,591 20,383 3 20,386 Both Direct and Indirect 941 586 1,527 1 1,528 Total 5,005 20,463 25,468 573 26,041 ESOP (No Common Stock) 5,809 5,809 5,809 Common Stock and ESOP 591 591 591 Total All Plans Holding Stocks 5,005 26,863 31,868 573 32,441 a  DOL calculations from the 2018 Form 5500 Pension Research Files. Ther…
  20. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    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…