IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCProposed Rules (FR)Proposed May 13, 2026
…r than 100 participants to be small entities.[185] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…er than 100 participants to be small entities.[42] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… 100 participants to be small entities.[359]
The basis of this definition is found in ERISA Section 104(a)(2), which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under ERISA Section 104(a)(3), the Secretary may also provide for exemptions or sim…
IRCCourt RulingsSep 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
IRCCourt RulingsOct 19, 2010related by meaning
ense that it caused.to surface a
meritorious section 72(t) issue and resulted in respondent's
I
"Respondent's concession is presumably based upon sec. 72(t) (2) (A) (iv), which provides that the 10-percent additional
tax does not apply to distributions which are "part of a series
of substantially equal periodic payment…
IRCCourt RulingsMay 14, 2012
…ross income are construed narrowly.
See Commissioner v. Schleier, 515 U.S. 323, 328 (1995). Section 104 provides in pertinent part as follows:
SEC. 104. COMPENSATION FOR INJURIES OR SICKNESS.
(a) In General.-Except in the case of amounts attributable to
(and not in excess of) deductions allowed under section 213 (relat…
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
77 FR 74063 — Amendments to the Abandoned Plan Regulations ERISAProposed Rules (FR)Proposed Dec 12, 2012
…yee benefit plan with fewer than 100 participants. The basis of this definition is found in section 104(a)(2) of ERISA that permits the Secretary of Labor to prescribe simplified annual reports for pension plans that cover fewer than 100 participants. Under section 104(a)(3), the Secretary may also provide for exemptio…
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
.
IRCFinal Rules (FR)Aug 26, 2022
…er than 100 participants to be a small entity.[93] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
IRCCourt RulingsJan 28, 2014related by meaning
…r return or a properly completed form
attached to the return. An analysis of petitioners' 2008 Form 1040 confirms that
they reported no taxable income from the 2008 distributions. Petitioners did not
disclose in their return relevant facts concerning the distributions. Accordingly,
they fail the first requirement of th…
86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAProposed Rules (FR)Proposed Oct 14, 2021
…enefit plan with fewer than 100 participants.[155] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for pension plans that cover fewer than 100 participants. Under section 104(a)(3), the Secretary may also provide for exempt…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
85 FR 81097 — Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage IRCFinal Rules (FR)Dec 15, 2020
…benefit plan with fewer than 100 participants.[37] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for pension plans that cover fewer than 100 participants. Under section 104(a)(3), the Secretary of Labor may also provide f…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…r than 100 participants to be small entities.[115] The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…
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 …
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
… fewer than 100 participants to be small entities. The basis of this definition is found in section 104(a)(2) of ERISA, which permits the Secretary of Labor to prescribe simplified annual reports for plans that cover fewer than 100 participants. Under section 104(a)(3) of ERISA, the Secretary may also provide for exemp…