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83 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-352 — Luisa Deal v. Commissioner
    IRCCourt RulingsOct 25, 1999
    T.C. Memo. 1999-352 UNITED STATES TAX COURT LUISA DEAL, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12757-98. Filed October 25, 1999. Luisa Deal, pro se. Yvonne M. Peters , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : Respondent determined a deficien…
  2. 29 C.F.R. § 4022.61(f) — Limitations on benefit payments by plan administrator.
    PBGCRegulationsJan 1, 2017
    e year of the proposed termination date, is $2,352.27 per month, payable in the form of a single life annuity at age 65. Because the participant is older than age 65, no adjustment is required under § 4022.23(c) based on the annuitant's age factor. The benefit form is a joint and survivor annuity (contingent basis), as…
  3. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …35 2003 160,000 69,687 53,150 2004 165,000 71,633 54,811 2005 170,000 74,170 56,472 2006 175,000 76,352 58,133 In view of his computation pursuant to section 415(b)(2)(C) of lower reduced benefit limits, respondent in the notice of deficiency further calculated allowable deduction limits. Since respondent computed lowe…
  4. IRCCourt RulingsAug 3, 1979related by meaning
    155. Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77. Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue. Respondent concedes …
  5. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA).[352]
  6. PLR 201149005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 9, 2011
    …ontracts in an amount equal to the Annuity Value for purposes of Revenue Ruling 55-119, 1955-1 C.B. 352, and each Trust shall recognize gain or loss as a result of such transfer in the tax year that includes such transfer as provided therein. 2. Each Trust will recognize gain or loss as a result of the sale of its Part…
  7. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ent years Activity Burden hours Equivalent burden cost Burden hours Equivalent burden cost Legal 10,352 $1,649,488 0 $0 Total 10,352 1,649,488 0 0 For the added requirement of a written statement informing the investor of their right to obtain a written description of the financial institution's policies and procedures…
  8. 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…
  9. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
  10. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  11. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  12. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  13. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  14. 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…
  15. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    …unt No. 015-268675 was as follows: - 11 - Date Withdrawal Deposit Balance 8/27/85 $1,333.20 --- $53,352.07 8/27/85 50,000.00 --- 3,352.07 10/15/85 --- $1,127.20 4,479.27 11/25/85 --- 1,333.20 5,812.47 12/03/85 5,500.00 673.91 986.38 1/13/86 14,500.00 13,654.49 140.87 4/14/86 --- 1,059.80 1,200.67 10/07/86 3.00 1,028.36…
  16. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998
    …03(h), 706(g)(1), and 717(a), (b), and (c) of title VII of the Civil Rights Act of 1964, Pub. L. 88-352, 78 Stat. 254, 257, 261, as amended. The opinion concludes that “employee” as used in section 704(a) of Pub. L. 88-352, 78 Stat. 257, is ambiguous and further concludes that the purposes of that section 704(a) would …
  17. 44 T.C. 335 — F. & D. Rentals, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1965
    …ed goods.. 353,677.93 111,687.77 324,986.69 353,677.93 111, 687.77 324,986.69 Total inventory.. 790,352.39 790,352.39 DEFERRED CHARGES Factory supplies.— Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14 Total deferred charges. 13,049.01 13,049.01 FIXED ASSETS
  18. 96 T.C. 644; 96 T.C. No. 24 — O'Malley v. Commissioner
    IRCCourt RulingsApr 15, 1991
    …. 1982). United States v. Williams, 737 F.2d 594 (7th Cir. 1984). O’Malley v. Commissioner, 91 T.C. 352 (1988). Since we have previously held petitioner’s legal expenses to be personal in nature, petitioner is estopped from now arguing that the legal fees were incurred in his capacity as fiduciary of the pension plan. …
  19. 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…
  20. 89 FR 64538 — Quality Control Standards for Automated Valuation Models
    IRCFinal Rules (FR)Aug 7, 2024
    …3909; 15 U.S.C. 1681s, 1681w, 6801 and 6805. 4. Add subpart O, consisting of §§ 225.350 through 225.352, to part 225 to read as follows: Subpart O—Quality Control Standards for Automated Valuation Models Used for Mortgage Lending Purposes 225.350 Authority, purpose and scope. 225.351 Definitions. 225.352 Quality contro…