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90 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans
    IRCNoticesJun 1, 2026
    …dment is provided in section 7 of Rev. Proc. 2023-37. However, Q&A J-1 of Notice 2024-2, 2024-2 IRB 316, provides additional guidance with respect to the deadlines for interim or discretionary amendments adopted to reflect applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L.…
  2. Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24…
    IRCNoticesJun 1, 2026
    …dment is provided in section 7 of Rev. Proc. 2023-37. However, Q&A J-1 of Notice 2024-2, 2024-2 IRB 316, provides additional guidance with respect to the deadlines for interim or discretionary amendments adopted to reflect applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L.…
  3. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    minable with reasonable certainty within the taxable year. Dixie Pine Co. v. Commissioner, 320 U.S. 516 (1944); sec. 1.461-1 (a) (2), Income Tax Regs. This record shows that in some instances petitioner contested its liability under the workmen’s compensation provisions. It is obvious without further discussion that un…
  4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  5. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995★ strong match
    …tain the effect of a distribution of property by the corporation to its shareholders. Secs. 301(c), 316(a). A distribution is treated as a dividend to the extent of the corporation’s earnings and profits. Sec. 316(a). If a distribution is made in excess of current and accumulated earnings and profits, the excess is tre…
  6. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …wing relevant amounts on its Federal income tax returns: 2001 2002 2003 Total incomel $2,527,967 $2,316,241 $2,137,828 Less: Total deductions 2,569,771 2,274,031 2,138,283 Taxable income (41,804) (223) (455) - 7 - 1Gross receipts less cost of goods sold. 2Amount includes deductions for net operatiing loss from 2001. In…
  7. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …dends at all, because a dividend is defined as a payment oy a corporation to its shareholders. Sec. 316(a). The SIP is the owner of the preferred stock; it cannot be the payor of dividends under section 316. These distribution payments represent only the distribution of the proceeds of a dividend paid ioy petitioner to…
  8. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026
    … agency of the Treasury Department, which includes the IRS. 9 Q&A J-1 of Notice 2024-02, 2024-2 IRB 316, sets forth the general deadlines for a plan sponsor to amend its eligible retirement plan for required and discretionary amendments to reflect the SECURE 2.0 Act. This notice extends the deadline for a plan sponsor …
  9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
  10. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    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…
  11. 85 FR 2303 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Jan 15, 2020
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, rate set 316 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 For plans with a valuation date Immediate annuity rate (percent) Deferred annu…
  12. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty. OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
  13. 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…
  14. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    … Review & Update Notice (Subsequent Years) 0 152,127 0.35 Average Mail Disclosure (20 participants) 316,513 316,513 0.73 Per Plan First Year Costs 2.13 Per Plan Subsequent Year Costs 1.08 * The cost per entity reflects the total costs of the regulation averaged to account for the 434,477 small, non-Federal group health…
  15. 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…
  16. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    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. …
  17. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
  18. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    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)…
  19. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    … whatever source derived including, inter alia, interest and dividends. Sec. 61(a)(4), (7). Section 316(a) defines dividends as any distribution of property made by a corporation to its shareholders to the extent of earnings and profits. Dividends may be formally declared, or they may be constructive. Noble v. Commissi…
  20. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …