ERISAProposed Rules (FR)Proposed May 8, 2013
ry's benefit statement might look something like this:
Current Balance
Projected Balance
$125,000
$557,534
Monthly Payment
Monthly Payment
$625
$2,788 This shows both total balances (current and projected) and the monthly payments generated by each. The projected balance ($557,534) and related monthly payment ($2,788) …
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…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…efore taxes
FY ended
taxes of GSI & subsidiaries
GSI & subsidiaries June 30, 1988 $4,302,286 $5,748,557
June 30, 1989 9,725,667 9,759,287
June 30, 1990 11,111,080 11,111,080
June 30, 1991 3,224,665 2,237,628
BI's transition from providing services only to local
merchants, service stations, and banks, to serving some la…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
6.46 6.68
H. Normal cost (beginning of year)
3
7,557,754 8,682,914 9,523,819 11,286,962
I. Benefits paid during year N/A 4,078,160 4,859,441 5,301,930 J. Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
498,812 896,239 1,225,134 1,454,591
L. Account limit (yearend)
5
8,056,566 14,…
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 RulingsApr 16, 2020
on payments of $30,557 for 2010, and respondent has conceded that this
amount is not subject to the additional tax. The record contains no evidence of additional qualified education expenses paid for 2010 or any qualified education
expenses paid for 2011.¹5
Accordingly, we find petitioners liable for the 10% additional…
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…1 (defined as the plan year and
limitation year in the ESOP's plan document). Mr. Essy received $41,557 and
$40,000 in wages in the 2000 and 2001 calendar years, respectively. There is no
information regarding the amount Mr. Essy specifically earned during the 12month limitation year from April 1, 2000, to March 31, 20…
IRCCourt RulingsApr 2, 2020
…ne 19.b, and the interest due was shown on line 19.c. For 2003, line 19.a showed the
tax due as $10,557; line 19.b (for penalties) was blank; and line 19.c showed the
interest due "computed to 05/29/2011" as zero (specifically "0.00"). The sum of
all three amounts due was shown as $10,557. For 2004, line 19.a showed th…
IRCCourt RulingsSep 25, 2000related by meaning
hould apply throughout ERISA
including the tax provisions. Because the Department of Labor
failed to issue final regulations on this point until 1992, petitioner contends that respondent is not in a position to argue
that separate definitions of a fiduciary apply for the two
titles. However, the absence of final regula…
IRCCourt RulingsJan 16, 1980
…e deductibility of the contributions is governed by section 404(a)(5). In Educo, Inc. v. Alexander, 557 F.2d 617, 622 (1977), the Seventh Circuit, in reference to plans administered by Educo, stated that such plans “are clearly characterizable as deferred-compensation plans.” The issue before the Court of Appeals in th…
IRCCourt RulingsJan 14, 2013related by meaning
ALS
T.C. Memo. 2013-10
UNITED STATES TAX COURT
THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners
V.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013.
1481-10.
R determined that a corporation's compensation packages for its
owner-employees were unreasonabl…
IRCCourt RulingsApr 11, 2012
…ing relevant amounts on its
income tax returns:
2001 2002 2003
Total incomel $719,437 $741,101 $881,557
Less: Total deductions 702,992 ' 741,037 882,456
Net operating loss
19 825 3,380 3,316
carryover >380 (3 316) (4,215)
Taxable income ; ( 3> ) '
IRCCourt RulingsJun 16, 1987related by meaning
iaries alike, providing assured protection to the former and clear notice of responsibility to the latter. [716 F.2d at 1464-1465. Citations omitted.] After a review of the statutory framework and legislative history of section 4975 and the case law interpreting ERISA section 406, we conclude that the prohibited transa…
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 RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
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…
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsMar 9, 2011★ strong match
…ted for those years DISC commissions
of $465,392, $334,315, and $297,052 and taxable income
of $463,557, $333,119,.and $294,657, 'respectively. ADF
deducted the payment of these DISC commissions to ADF
International·.
(2) As a result of its status as a-DISC, ADF
International was deemed to have made distributions of
. …
ERISACourt RulingsAug 10, 2026
…o the p lan administrator directly (quoting § 1024(b)(4)) ); Mondry v. Am . Fam . Mut. Ins . Co . , 557 F.3d 781, 796 (7th Cir. 2009) (holding that § 1024(b)(4)
require d the production of a claims administration agreement because , in defin ing the
respective roles of the plan and claims administrators , the agreement…