IRCCourt RulingsJan 26, 2006
…ection
7491(a)(2). Therefore, the burden of proof remains with
petitioner.
II. Distributions of $15,322.69 and $7,000
A. General
Section 408(d)(1) provides that any amount paid or
distributed from a qualified retirement plan generally must be
included in gross income by the distributee in the manner
provided under sect…
IRCRegulationsSep 17, 2024
…the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on January 1, 2006, of the loan it repl…
IRCCourt RulingsJul 31, 2000
…e end of that year, the
conversion credit balance was $7,485.21 ($4,865.74 + $2,962.50 -
$665.36 + $322.33); the $322.33 is the interest of 4.5 percent
earned on the conversion credit balance (($7,485.21 - $322.33) x
4.5% = $322.33)). Of the conversion credit balance, $6,755.40
could have been transferred at this time …
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…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…ations
693,105 = 770,117 Plans × 90% Using a Service Provider
5/60
70.29
57,759
4,059,862
Total
138,322
$18,646,718
Table 8—Cost for Distribution of New Paper Benefit Statements for 2020 Safe Harbor
[Year 1]
Description
Affected entities
Pages per
disclosure
Material costs per
page
Distribution
costs per
disclosure
Tot…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsFeb 6, 1992related by meaning
fic terms and requirements that, in a reasonable manner, interpret and carry out the general concepts embodied in the statute and legislative history. Thus, we hold that the temporary regulation is valid.
Applicability of Temporary Regulation to Petitioner's Yearend Bonus Payments
In the alternative, petitioner argues …
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
… hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Insurance Sales Agent
250,000
$41,322,500
250,000
$41,322,500
Total
250,000
41,322,500
250,000
41,322,500
1.3.1.5 Mailing Cost for Disclosures Sent From Independent Producers to Retirement Investors
As discussed at the beginning of the cost section, the …
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
.
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
85 FR 42706 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Jul 15, 2020
…S
1. The authority citation for part 4022 continues to read as follows:
Authority:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, rate set 322 is added at the end of the table to read as follows:
Appendix B to Part 4022 — Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsJan 30, 2007
…ll Lynch, to protect
Taxable income
Cash Pay 123,000 Merrill Lynch,
to protect
Taxable income
Other 322,962 Merrill Lynch,
to protect
Taxable income
Total 1,118,870
Petitioners reported taxable income of $213,977, tax of $60,080,
tax on IRAs and other retirement plans of $63,717, and total tax
4(...continued)
2000.
- 1…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…f affected entities in section IV.C.
Back to Citation
278.
The burden is estimated as follows: 149,322 plans × 4 hours = 597,288 hours. A labor rate of $153.21 is used for a legal professional. The cost is estimated as follows: 149,322 plans × 4 hours × $153.21 = $91,510,494.
Back to Citation
279.
The per-plan burden…
IRCCourt RulingsJun 18, 1997related by meaning
ity under an annuity, endowment, or
life insurance contract to the extent such an amount is
attributable to the taxpayer's investment in the contract. Section 1.72-15(b), Income Tax Regs., provides that, as a general
rule, section 72 does not apply to any amount received as an
accident or health benefit.
Section 104(a)…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
ERISACourt RulingsAug 10, 2026
… for appropriate remedies, sanctions, and ready access to the Federal
courts.’ ” Marks v. Watters , 322 F.3d 316, 322 (4th Cir. 2003) (quoting 29
U.S.C. § 1001(b) ).
USCA4 Appeal: 25-1350 Doc: 89 Filed: 08/10/2026 Pg: 3 of 21
4
As to Kelly’s third claim, h e allege d that, despite his request, the p lan administrator
r…
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…
IRCCourt RulingsMar 13, 2001
…iding for it by statute.
See, e.g., secs. 1(f), 151(d)(4); Bartley v. Commissioner, T.C.
Memo. 1998-322 n.10.
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