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89 documents · 0.24sAllIRCERISAPBGCJoint 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. 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…
  3. 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…
  4. 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…
  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. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    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…
  10. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    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…
  11. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  12. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    er husband and he was injured at the time of his early retirement, she should be taxed in the same manner as her former husband. A versiori of section 104(a)(1) allowing an injured person to exclude disability income from his or her taxable income has been in the Code since the Revenue Act of 1918 when it was added bec…
  13. 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…
  14. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    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…
  15. 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 …
  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. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007related by meaning
    s were attributable to disability, or that the distributions otherwise qualify for an exception to the 10-percent additional tax. In fact, petitioners state on brief that "Petitioners do understand that petitioners have to pay 10% penalty tax on the amount stated above * * * This is consistent with IRC section 72(t) (1…
  18. 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
  19. 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…
  20. 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. …