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1. ERISA § 4301(a) (29 U.S.C. § 1451) — Civil actions
   PBGCCode / StatuteJan 4, 1995
   (a) (a) Persons entitled to maintain actions (a)(1) (1) A plan fiduciary, employer, plan participant, or beneficiary, who is adversely affected by the act or omission of any party under this subtitle with respect to a multiemployer plan, or an employee organization which represents such a plan participant or beneficiar…
2. 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…
3. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
   IRCCourt RulingsDec 8, 1987
   …e prohibited transaction restrictions of section 4975(c). See Lambos v. Commissioner, 88 T.C. 1440, 1451 (1987).
4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
5. PLR 201330016 — Required Distributions Where Holder Dies
   IRCPrivate Letter RulingsJul 26, 2013
   …ome of the decedent, is treated as a premium paid for the contract. H.R. Rep. No. 98-432 (Pt II) at 1451 (1984). The Senate amendment provided that [i]f the owner of any annuity contract dies before the annuity starting date, the specific distribution r ules would apply, depending on decedent’s beneficiary with respect…
6. 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…
7. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
   IRCCourt RulingsJan 6, 1997
   … the intent of the parties, and such intent is a question of fact. Stamos v. Commissioner , 87 T.C. 1451, 1455 (1986). Ordinarily, a stipulation of fact is binding on the parties, and we are constrained to enforce it. Rule 91. We shall not permit a party to a stipulation to qualify, change, or
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. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
   IRCCourt RulingsSep 27, 1990
   …); see H. Conf. Rept. 93-1280, 1974-3 C.B. 415, 467 n. 2; cf. Lambos v. Commissioner, 88 T.C. 1440, 1451-1452 (1987). Nothing in the provisions dealing with private foundations, however, persuades us that an unexpressed distinction between voluntary and required contributions should be read into the provisions dealing …
10. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
11. 101 T.C. 518; 101 T.C. No. 34 — Janpol v. Commissioner
    IRCCourt RulingsDec 7, 1993
    …lved. See Rutland v. Commissioner, 89 T.C. 1137, 1151 (1987); Lambos v. Commissioner, 88 T.C. 1440, 1451-1453 (1987); cf. Hockaden & Associates, Inc. v. Commissioner, 800 F.2d 70 (6th Cir. 1986), affg. 84 T.C. 13 (1985). Petitioners contend that the “net increase over the year” is the only amount that should be subject…
12. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    Motion for a Section 6673 Penalty Respondent submitted a motion for the imposition of a penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous,…
13. 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 .
14. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
15. ERISA § 4003(f)(5)(B)(ii) (29 U.S.C. § 1303) — Operation of corporation
    PBGCCode / StatuteJan 6, 2017
    …In any suit, action, or proceeding in which the corporation is a party, or intervenes under section 1451 of this title, in any State court, the corporation may, without bond or security, remove such suit, action, or proceeding from the State court to the United States district court for the district or division in whic…
16. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
17. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
18. 29 C.F.R. § 2570.133 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
19. 35 T.C. 1217 — Searl v. Commissioner
    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…
20. 93 T.C. 79; 93 T.C. No. 8 — McManus v. Commissioner
    IRCCourt RulingsJul 24, 1989related by meaning
    eceiving from the IRS only the acknowledgment of the applications, two phone calls from Ms. Islas and the final adverse determination letters. OPINION Section 7476 creates a judicial remedy for taxpayers seeking determinations of qualification of retirement plans under section 401(a), which latter section lists the cha…