IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJun 25, 2013
…P account as outlined in the MSA.
In 2007, and pursuant to the amended MSA, petitioner withdrew $25,248
from the TSP account, which constituted his entire 50% interest. Also pursuant to
the amended MSA, once petitioner received the distribution check, he transferred
$24,248 to Ms. Toombs
Petitioner paid a commercial ta…
IRCRegulationsSep 17, 2024★ strong match
…tribution requirements added by the Tax Equity and Fiscal Responsibility Act of 1982, Public Law 97-248, 96 Stat. 324 (1982) (TEFRA), were retroactively repealed in 1984, the transitional election rule in section 242(b) of TEFRA (referred to as a section 242(b)(2) election in this paragraph (h)) was preserved. While se…
77 FR 74063 — Amendments to the Abandoned Plan Regulations ERISAProposed Rules (FR)Proposed Dec 12, 2012
…uired to prepare required plan information, and to review and sign the forms. This results in about 248 hours (495 plans × .5 hours) of clerical staff time with an associated cost burden of $7,000 (495 plans × .5 hours × $28.21 per hour), and 248 hours (495 plans × .5 hours) of a financial professional's time with an a…
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. …
IRCCourt RulingsDec 2, 1981related by meaning
of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
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
…47
.03 Opinion and advisory letters
247
.04 VCP compliance statements – electronic submissions only
248
SECTION 32. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS?
248
SECTION 33. EFFECTIVE DATE
248
SECTION 34. PAPERWORK REDUCTION ACT
248
DRAFTING INFORMATION
249
APPENDIX A SCHEDULE OF USER FEES
250
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…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…duced out-of-pocket costs for participants (the sum of the copayment and coinsurance) by 1 percent.[248]
IRCCourt RulingsDec 15, 2009
…tributions
from the IRA in .the following amounts : $69,330 ; $44,200 ;
$81,096 ; $80,039 ; and $66,248, respectively . Each of these amounts was reported on a Form 1099-R designating a distribution
code 3 indicating an early distribution due to,disability . The
fair market value of the IRA account at the end of 2005 w…
IRCCourt RulingsMar 24, 2000
…rldly Connections, Inc. The documentation submitted indicates that in January 1994 petitioner
paid $248.95 for Delaware State filing fees, registered agent
fees, a corporate kit, and basic mail forwarding service.
Petitioner also remitted an additional $155 in November 1994 for
advanced payment of agent fees and renewa…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
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…
IRCCourt RulingsMar 27, 1989related by meaning
ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan.
Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
79 FR 27731 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)May 15, 2014
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 248, as set forth below, is added to the table.
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a valuation date
Immediate
annuity rate
(percent)
Deferred annuities
(pe…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
IRCCourt RulingsJun 17, 1997★ strong match
…545
Surrender value 157,104 157,104 166,613 161,097 162,772
Addit. contr. available 202,263 197,155 248,761 243,663 296,318
Date of report 09/94 03/95 09/94 03/95;10/95 10/95
On March 31, 1989, Prime forwarded to On-Site its 1988
summary plan description. On April 4, 1990, Prime forwarded to
On-Site its 1989 summary pl…
IRCProposed Rules (FR)Proposed Oct 5, 2022
…costs to calculate indirect costs of $990,531, for a total cost for the three-year period of $2,674,248. The calculation of the total cost of the enrolled actuary enrollment and renewal of enrollment program for 2022 through 2024 is shown below:
( printed page 60361)
Direct Costs
$1,683,717
Overhead at 58.83%
+ 990,531…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
…7 Opinion letters on § 403(b) prototype plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28
248
.08 Opinion letters on pre-approved plans submitted pursuant to Rev. Proc. 2023-x37 (§ 401(a))
248
.09 Advisory letters on § 403(b) VS plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28
248
.10 Determination…