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85 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    t to which the restrictions apply) has exhausted all remedies prescribed by foreign law or practice for obtaining a waiver of such restrictions (other than remedies that would have a negligible prospect of success if pursued); (C) The restrictions expressly prevented the payment or receipt, i n any form, of part or all…
  2. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …ice providers who provided services of “Investment Management” and “Named Fiduciary,” of which only 765 reported their business code. Out of these 765 providers, 339 reported their business code starting with the 2-digit NAICS code 52, yielding a ratio of 0.44 of potential QPAMs to other providers. Therefore, the Depar…
  3. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    .a distribution of $6,277 from a qualified retirement . plan during~the'2001 tax year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that she qualified for any of the . exceptions in section 72(t)(2) . Accordingly ; we hold that Ms .-O'Boyle…
  4. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995
    ….78, was paid by check dated May 31, 1990. Petitioner's Transfer Refund of $158,680.98 includes $21,765.02 in previously taxed contributions and $136,681.18 of earnings. 5 The earnings represent interest and constitute the taxable portion of that part of the Transfer Refund that was paid - 5 - 6 Petitioner initially ro…
  5. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  6. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    … Entities   Prohibited transaction exemptions 2020-02 75-1 77-4 80-83 86-128 84-24 Retirement Plans 765,124 765,124 277,390 6,312 1,000 1,722 Individual Retirement Account owners 67,781,000 210 500,000 Broker-Dealers 1,920 1,920 Discretionary Fiduciaries 251 Registered Investment Advisers 16,398 Pure Robo-Advisers 200 …
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    that the Court vacate its Order [sic] of August 16 and order the parties to submit computations pursuant to Rule 155. This will permit the parties the opportunity to determine whether TLC's liability should be reduced by the amounts already paid by parties to the transaction. On the record before us, we reject petition…
  8. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  9. 71 T.C. 765 — Elliot Knitwear Profit Sharing Plan v. Commissioner
    IRCCourt RulingsFeb 12, 1979
    …iot Knitwear Profit Sharing Plan v. Commissioner Docket No. 2725-77 United States Tax Court 71 T.C. 765; 1979 U.S. Tax Ct. LEXIS 175; February 12, 1979, Filed *175 Decision will be entered for the respondent. Petitioner is the trustee of a qualified profit sharing plan. Pursuant to his authority as trustee, petitioner …
  10. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …in greater detail later below. Table 2—Affected Entities   Total ERISA-Covered Group Health Plans 2,765,373 TPAs 205 Issuers in the group market 373 Issuers/state combinations in the group market 811 1. Group Health Plans, Participants, and Beneficiaries The proposed rule would affect ERISA-covered group health plans. …
  11. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    … Property — 1951 Total 100% Feldspar 25% Silica 77% Tons produced and shipped_ 113, 981 26, 216 87, 765 Relative value times weight per-centages_ 100% 31. 6% 68. 4% Gross income from property: Unseparated product at $4.99/ton_ $568, 765. 19 $179, 729. 80 $389, 035. 39 Byproduct sales_ 1, 345. 05 1, 345. 05 Less royalti…
  12. 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…
  13. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  14. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    ests between 2022-2024 to be $356,727,765 (inclusive of printing, materials, mailing costs) and total burden hours of 3,538,305, as shown in Table 44. HHS estimates the annual cost for printing and materials to provide written good faith estimates to uninsured (or self-pay) individuals to be $314,905. The mailing costs…
  15. 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…
  16. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  17. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
  18. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  19. 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…
  20. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    s + 2 bulk applications = 1,237. Back to Citation 53.  In 2021, there were 765,124 pension plans. ( Source: Employee Benefits Security Administration, Private Pension Plan Bulletin: Abstract of 2021 Form 5500 Annual Reports, (September 2023).) In 2022, there were 630,000 welfare benefit plans. ( Source: U.S. Department…