IRCCourt RulingsFeb 9, 2023
…e of any of such organizations, tra des, or
businesses.
Section 482 of the Internal Revenue Code of 1954 applied only to tax years that began after December 31, 1953, and ended after August
16, 1954. Internal Revenue Code of 1954, sec. 7851(a)(1)(A), 68A Stat.
at 919 , 929.
107
Thus for calendar- year taxpayers, 1954 w…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961
petitioner’s books and records as an expense for its taxable year 1954 and was claimed as a deduction on its income tax return for such taxable year. Respondent disallowed the deduction claimed for the stated reason that “the amount of $5,100.00 claimed as a deduction for a ‘gratuity to Mrs. J. R. Bacon’ on Form 1120 …
IRCCourt RulingsApr 18, 1960
…. Minutes of each of these meetings were kept, but were not presented in evidence. On September 13, 1954, the petitioner wrote the district director of internal revenue at Portsmouth, New Hampshire, concerning the effect which the Internal Revenue Code of 1954 might have on the situation outlined in Fels’ letter. On Se…
IRCCourt RulingsJun 4, 1984related by meaning
recognition that various provisions of ERISA were enacted in large part to replace the plan disqualification sanction with other pecuniary sanctions. In ERISA, Congress reacted to perceived abuses in the administration of employee benefit plans by establishing new and stricter standards of fiduciary responsibility, by…
IRCCourt RulingsSep 29, 1992related by meaning
…t of Actuaries (Joint Board) established under the Employee Retirement Income Security Act of 1974 (erisa), Pub. L. 93-406, 88 Stat. 829. Sections 412(c)(3), 6059, and 7701(a)(35) were added to the Internal Revenue Code by ERISA sections 1013(a), 1033(a), and 3043, 88 Stat. 914, 947, 1003, to apply for plan years begin…
IRCCourt RulingsJun 16, 1987related by meaning
…years, and all Rule references are to the Rules of Practice and Procedure of this Court. Title I of ERISA sets forth guidelines and standards governing the establishment and operation of pension plans and also establishes general standards of conduct for plan fiduciaries. See generally ERISA sec. 2 et seq., 88 Stat. 83…
IRCFinal Rules (FR)May 23, 2022related by meaning
… U.S.C. 1002(43). The term pooled employer plan does not include a multiemployer plan as defined in ERISA section 3(37) and also does not include a plan established before the date the SECURE Act was enacted unless the plan administrator elects to have the plan treated as a pooled employer plan and the plan meets the E…
38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner IRCCourt RulingsSep 21, 1962
…e tax for the years and in the amounts as follows:
Year Deficiency
1952_$4,998.08
1953_ 21, 500. 66
1954_ 17, 086. 45
1955_ 48, 532.33 By amended, petition, petitioner alleged that it sustained a net operating loss for its taxable year 1957, thus becoming entitled to a net operating loss deduction for its taxable year …
88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023related by meaning
… consumer protections and requirements for comprehensive coverage. In general, through section 514, ERISA supersedes State laws to the extent that they relate to any covered employee benefit plan, and preserves State laws that regulate insurance, banking, or securities. While ERISA prohibits States from regulating an e…
IRCCourt RulingsJan 27, 1998related by meaning
…ve occurred or
in those circumstances where the Department of Labor has not undertaken a response."
ERISA was enacted in 1974, setting up an administrative
system for employee benefit plans. ERISA section 2(b), 88 Stat.
829, 833, provides that
the policy of this Act [is] to protect interstate
commerce and the interests…
IRCFinal Rules (FR)Feb 24, 2023related by meaning
…BSA (3272) or visit the DOL's website (
www.dol.gov/agencies/ebsa).
SUPPLEMENTARY INFORMATION:
A. ERISA Reporting Framework Titles I and IV of the Employer Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code (Code) generally require pension and other employee benefit plans to file annual retu…
IRCCourt RulingsAug 10, 1961
….
Petitioner paid total premiums of $18,742.25 on the Connecticut Mutual policy. As of December 22, 1954, the total cash surrender value of said policy was $26,813.54, including accumulated dividends of $263.40 and interest thereon of $70.14.
On December 14,1954, petitioner executed an assignment of all his “right, tit…
IRCCourt RulingsNov 5, 1999related by meaning
andards for fiduciary
behavior set forth in the Employee Retirement Income Security Act
of 1974 (ERISA), Pub. L. 93-406, sec. 404(a)(1), 88 Stat. 877, current version at 29 U.S.C. sec. 1104 (1994), may be used to
help determine whether the exclusive benefit rule has been
violated. See Ada Orthopedic, Inc. v. Commission…
IRCCourt RulingsJan 16, 1963
…ned deficiencies in income tax of petitioners William and Milbrey W. Waller, for the calendar years 1954 and 1955, in the respective amounts of $6,125.59 and $16,256.52, and in income tax of petitioner William Waller for the calendar year 1958 in the amount of $1,942.28.
A number of concessions have been made by the pa…
IRCCourt RulingsJul 24, 1991related by meaning
…ctment of the Employee Retirement Income Security Act of 1974 (hereinafter sometimes referred to as ERISA), Pub. L. 93-406, 88 Stat. 829, attachments of a participant’s interest in a tax-qualified plan were not prohibited by the Internal Revenue Code. Section 1021(a) of ERISA added Code section 401(a)(13), which requir…
IRCCourt RulingsAug 3, 1979related by meaning
…n 2002 of the Employee Retirement Income Security Act of 1974 (hereinafter sometimes referred to as ERISA), Pub. L. 93-406, 88 Stat. 958. Examination of the legislative history makes it clear that the Congress was concerned about strengthening employee benefit arrangements, largely to be sure that benefits that appeare…
IRCCourt RulingsMar 23, 1987related by meaning
…not permit any reversion of employer contributions other than a reversion specifically permitted by ERISA section 403(c)(2). ERISA was enacted to remedy perceived defects in the private retirement system. ERISA was designed to protect the rights of employees participating in private retirement plans, and to make the sy…
IRCCourt RulingsJul 14, 1992related by meaning
…rent taxpayer groups concerned. [H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 243.] The enactment of ERISA mandated a cooperative effort whereby the Department of Labor (Labor) and the Department of the Treasury (Treasury) would jointly oversee the participation in and vesting and funding of pension plans, the reporting…
IRCCourt RulingsMay 15, 1978related by meaning
… section 3002(c) of the Employee Retirement Income Security Act of 1974 (hereinafter referred to as ERISA) which provides: Regulations prescribed by the Secretary of Treasury under sections 410(a), 411, and 412 of the Internal Revenue Code of 1954 (relating to minimum participation standards, minimum vesting standards,…
34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960
…Corporation Profit Sharing Trust. Two employee trustees were elected on the second Tuesday of March 1954. At a meeting of the board of directors on March 26, 1954, Harris was elected as the company trustee representative. The first meeting of the trustees of West Virginia Steel Corporation Profit Sharing Trust was held…