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82 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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
    …tation 118.  The hour burden is estimated as: (1 application × 3 hours) = 3 hours. A labor cost of $535.85 is applied for an outside legal professional. The equivalent cost is estimated as: (1 application × 3 hours × $535.85 outside legal professional labor) = $1,608 rounded to $1,600. Back to Citation 119.  87 FR 4520…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  3. T.C. Summary Opinion 2009-156 — Dean Gochis v. Commissioner
    IRCCourt RulingsOct 13, 2009
    …vidua l retirement plan account within 60 days . Sec . 408(d )(3)(A)(i) . Petitioner received a $38,535 distribution from his ASLA C individual retirement annuity . Petitioner requested that Scottrade deposit it into an IRA at Scottrade so that it could be rolled over into an individual retirement plan account within 6…
  4. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    …ntract did not qualify as a nontaxable exchange under section 1035 and that petitioner received $30,535 of unreported taxable income relating thereto. Respondent also determined that petitioner is liable under section 72(q) for a 10-percent penalty of $3,054 on the $30,535 portion of the withdrawal from the Fortis annu…
  5. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985★ strong match
    …971). We have followed this approach in many cases. E.g., Van Sant v. Commissioner, T.C. Memo. 1984-535; Craine v. Commissioner, T.C. Memo. 1984-513; Pizor v. Commissioner, T.C. Memo. 1979-487; Kacin v. Commissioner, T.C. Memo. 1979-410; Cooper v. Commissioner, T.C. Memo. 1979-256. See also Day v. Commissioner, T.C. Me…
  6. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …t Producer and two hours for a legal professional at an insurer, resulting in an hour burden of 173,535 hours and an equivalent cost of $28.7 million.[106] Table 14—Hour Burden and Equivalent Cost Associated With the Recordkeeping Requirement Activity Year 1 Subsequent years Burden hours Equivalent burden cost Burden h…
  7. 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…
  8. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  9. 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…
  10. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    …− $86,384) is the increase in the present value of the future payment for X’s 2017 taxable year; $4,535 ($95,238 − $90,703) is the increase in the present value of the future payment for X’s 2018 taxable year; and $4,762 ($100,000 − $95,238) is the increase in the present value of the future payment for X’s 2019 taxabl…
  11. PLR 200117038 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 27, 2001
    … in Boxes 1, 3, and 5, as “ wages, ” “ social security wages ” and Medicare wages. See Publications 535 and 15-A for additional information. Question #45: What remuneration under a cafeteria plan is not subject to FICA, FUTA, Medicare tax or income tax withholding? Answer: Generally, qualified benefits under a cafeteri…
  12. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …s 9,166 Prior year State refund 1,912 Dividend income 1,312 Interest income 31 SE AGI adjustment (6,535) Standard deduction (5,150) Exemptions (3,300) Corrected taxable income1 89,936 Respondent used a filing status of "single".
  13. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018★ strong match
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  14. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  15. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
  16. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    … Bulletin. (ii) The present value of Retiree D's straight life annuity on the valuation date is $10,535.79.
  17. 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 .
  18. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …posed levy."). Additionally, we do not understand the dissent's citation of United States v. Craft, 535 U.S. 274, 283, 288 (2002), and Notice 2003-60, 2003-2 C.B. 643, 645. S_e_e dissenting op. p. 89. As we have explained, see supra note 25, as of the time of the CDP hearing Mr. Melasky cannot possibly have held the Ex…
  19. 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. …
  20. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…