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98 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
  2. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …given the almost innumerable appropriate options available to fiduciaries. Chao v. Merino, 452 F.3d 174, 182 (2d Cir. 2006) (ERISA does not require a fiduciary to take “any particular course of action” so long as the fiduciary's decision meets the prudent person standard). Therefore, the Supreme Court has instructed th…
  3. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …verage of excepted fertility benefit. Back to Citation 151.  The estimate is calculated as: (36,384,174 participants aged 25 to 45 enrolled in non-federal, employer-sponsored health insurance without offer of fertility coverage in group plan × 65.8 percent offer rate) + (13,457,160 participants aged 25 to 45 enrolled i…
  4. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997
    …d. 930 F.2d 372 (4th Cir. 1991); Green v. Commissioner , 83 T.C. 667, 686-687 (1984). Thus, section 174 might require a lesser showing than section 162 of the trade or business activities actually conducted by petitioner in 1990. Nonetheless, we conclude that section 174 does not help petitioner because the record in t…
  5. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    … statement 173 SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE? 174 .01 In general 174 .02 Determination Letters 174 .03 Letter Rulings 174 .04 Voluntary Closing Agreements 174 .05 Other Matters 174 SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES…
  6. 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…
  7. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …tment of certain contributions under § 414(h) 173 .07 Other limits on scope of determination letter 174 .08 Leased employees 174 .09 Partial terminations 174 .10 Publication 794, Favorable Determination Letter 174 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 174 .01 Scope 174 .02 Comp…
  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. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …increases to avoid paying additional rebates under the price protection terms in the PBM contracts.[174] As such, while both PBMs and self-insured group health plans could potentially benefit from price protection rebates, rebate practices also add an additional layer of complexity to contracts which can make it hard t…
  10. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 173 .01 Scope 173 .02 Complete information required 174 .03 Complete copy of plan and trust instrument and applicable amendments required 174 .04 Separate application for each single § 414(l) plan 174 .05 Prior letters 174 .06 Plans involving mergers 174 .07 User fees 174…
  11. IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
  12. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012★ strong match
    …plied. They apparently assume--erroneously--that relaxed rules of procedure and evidence under Rule 174(b) relieve them of the necessity of timely and appropriate evidence and arguments based on applicable law. Rule 174(b), however, refers to consistency with "orderly procedure" and requires evidence that has "probativ…
  13. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ete applications 172 .13 Effect of failure to disclose material fact 173 .14 Where to file requests 174 .15 Submission of related plans 174 .16 Withdrawal of requests 174 .17 Right to status conference 174 .18 How to request status conference 174 .19 Correct format required 174 SECTION 11.WHAT IS THE PROCESS FOR REQUES…
  14. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    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 …
  15. PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsSep 25, 2009
    …ovide for periodic payments that will liquidate a fund. For example, in Igleheart v. Commissioner , 174 F.2d 605, 606 (7th Cir. 1949), the court stated that “an annuity has as its basic function the systematic liquidation of the principal.” Se e also Comm’r v. Meyer , 139 F.2d 256 (6th Cir. 1943). Similarly, in Rev. Ru…
  16. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  17. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …lies dominion or control of the taxpayer. * * * Commissioner v. First Sec . Bank , 405 U.S. at 404. 174 First Security Bank then quoted the “complete power” sentence from 26 C.F.R. sec. 1.482-1(b)(1) (1971), 175 explaining that the “complete-power” sentence “is consistent with the control concept heretofore approved by…
  18. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …ION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 173 .01 In general 174 .02 Letter ruling 174 .03 Closing agreement 174 .04 Determination letter 174 .05 Opinion letter 174 .06 Oral advice 175 .07 Nonbank trustee approval letters 175 .08 Compliance statement 176 .09 Advisory letter 176 SE…
  19. 81 T.C. 735; 81 T.C. No. 44 — Bricklayers Ben. Plans, Inc. v. Commissioner
    IRCCourt RulingsOct 13, 1983related by meaning
    arly fall outside the coverage of sec. 501(c)(9). However, respondent does not raise this argument and, thus, it is unnecessary for us to consider it. Petitioner alternatively argues that if it is reasonable to exclude pension benefits under sec. 501(c)(9), then sec. 1.501(c)(9)-3(e), Income Tax Regs., which permits va…
  20. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996
    …cluded therein. II. The IRA Distribution Issue On or about August 8, 1990, petitioner withdrew $157,174 from his IRA with First National. Petitioners reported $150,000 of this distribution in their gross income for 1990. Respondent contends that for 1990, petitioners failed to include in their gross income $7,174 of pe…