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93 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    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…
  2. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …$549,693 SCC (annual) 355,910 −355,910 VFCP Exemption (annual) 120,236 120,236 0 Total (annual) 885,806 692,023
  3. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997★ strong match
    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. …
  4. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ent advisers × 10%) + (8,412 state-registered investment advisers × 10%) + (183 insurers × 10%) = 1,806 financial institutions updating existing disclosures. The number of financial entities needing to draft their written acknowledgement is estimated as: 200 robo-advisers + 1,011 pension consultants + 20 investment com…
  5. 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…
  6. 81 FR 92316 — Claims Procedure for Plans Providing Disability Benefits
    ERISAFinal Rules (FR)Dec 19, 2016
    …tion to evaluate the claims process and defend their rights under their plan. Costs: Annualized $15,806,000 2016 7% 2018-2027 Monetized 15,806,000 2016 3% 2018-2027 ( printed page 92333) Qualitative
  7. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …or-profits. Estimated Number of Respondents: 1,151,392. Estimated Number of Annual Responses: 2,730,806. Frequency of Response: Annual, Semi-annual.
  8. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    gs in the Court, as follows: Trucking Company Client Case at Docket No. John and Kimberly Kohler 1026-01 (NBS Trucking) Joseph and Barbara Hix 1062-01 (Joe Hix Trucking) Blachowske Truck Line, Inc. 1107-01 Jones Brothers Trucking, Inc. 1149-01 Lake State Transport, Inc. 1286-01 Schak Trucking Inc. 1287-01 Donald Fierec…
  9. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ent advisers × 10%) + (8,412 state-registered investment advisers × 10%) + (183 insurers × 10%) = 1,806 financial institutions updating existing disclosures. [(1,806 financial institutions × 10 minutes) ÷ 60 minutes] = 301 hours. The equivalent cost is estimated as: 301 hours × $159.34 = $47,961. Back to Citation 33.
  10. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  11. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…
  12. 89 FR 43636 — Abandoned Plan Regulations
    ERISAFinal Rules (FR)May 17, 2024
    … (NBU22000000000000227372 & NBU22000000000000127372) for 2021 data. Back to Citation 56.  1,800 ≉ 1,806 = [(12,900 CHPT 7) × (48% small plans offering DC plans) × (75.3% proportion of small plans) × (10% abandonment rate of plans with firms in CHPT 7)] + (1,340 plans currently using the program); 11,500 participants ≉ …
  13. 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…
  14. 84 FR 67186 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 9, 2019
    …736 736 3,110 3,110 2026 753 753 3,181 3,181 2027 771 771 3,254 3,254 2028 788 788 3,329 3,329 2029 806 806 3,406 3,406 2030 or later 825 825 3,484 3,484 1  Applicable tables for valuation dates before 2020 are available on PBGC's website ( www.pbgc.gov). 2  Table II-A. 3  Table II-B. 4  Table II-C. * * * * * Issued in…
  15. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …rough independent channels and will rely on PTE 84-24 for transactions involving investment advice.[806]
  16. 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 …
  17. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010
    … after having been informed that his basis * * * is groundless." Greenberg v. Commissioner, 73 T.C. 806, 814 (1980). In Dew v. Commissioner, 91 T.C. 615, 626 (1988), the Court imposed a I section 6673 penalty against taxpayer, when he "persisted in
  18. T.C. Summary Opinion 2011-71 — Joseph B. & Rosemary A. Niesen v. Commissioner
    IRCCourt RulingsJun 16, 2011related by meaning
    ns allowed by this subtitle which are attrib table to such trade or business". Compensation excludes any amounts received as interest and dividends, a pension or annui y, and Social Security benefits. Secs. 219(f) (1), 401(c (2), 86(f) (3); see Miller v. Commissioner, 77 T.C. 97, 102 (1981). The other adjustments in th…
  19. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961
    …s that your share of the distributable net loss for the year February 1 to December 31, 1952 is $55,806.31. Inasmuch as you reported a net loss of $72,784.81, your taxable income is increased $16,978.50, computed as follows: Ordinary net loss per partnership return_ ($206,046.41) Add: Wages paid in contravention of the…
  20. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    luded that the bulk of the $26 million received by hi s IRA was attributable to his relinquishment of rights under the non- ESOP deferred compensation plans, which were not eligible for tax-free rollover. It accordingly determined t hat $25,132,892 of the $26 million constituted an “excess contribution” to his IRA unde…