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…
IRCCourt RulingsJun 10, 1996related by meaning
mount necessary to fund the
benefits payable under section 415 determined at the time of the
contribution in question. Citrus Valley Estates, Inc. v
. Commissioner
, 99 T.C. at 447. The dispute in these cases focuses
on the amounts of benefits payable under section 415 determined
at the time of the contributions in que…
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 RulingsJan 17, 2024related by meaning
… the Motion and not as findings of fact in this case. See
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this
case would apparently lie to the U.S. Court of Appe…
IRCCourt RulingsFeb 6, 1992related by meaning
n is subject to section 404. It is difficult, if not impossible, to discuss deferring receipt of compensation without focusing on the time of payment. We also reject petitioner's contention that the case at hand is similar to that in Minahan v. Commissioner, 88 T.C. 492 (1987). We held, in that case, that the Secretary…
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 RulingsMay 29, 2002related by meaning
to the additional tax under
section 72(t) and distinguished Larotonda and Murillo on the
ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is
equally true of the distribution here.
- 5 -
To reflect the foregoing,
An appropriate order of
dismissal a…
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…
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…
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…
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…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
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 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 …
IRCCourt RulingsJun 18, 1997★ strong match
…al
rule, section 72 does not apply to any amount received as an
accident or health benefit.
Section 104(a) excludes from gross income any amounts
described in paragraphs (1) through (5) of that section.
Paragraphs (4) and (5) of section 104(a) are, on their face,
inapplicable to the facts before us, and we focus our at…
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 RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
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…
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…enefit plan with fewer than 100 participants.[121] 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…
IRCCourt RulingsJul 6, 2022related by meaning
…ner’s M oti on and not as
findings of fact in this case. Sundstrand Corp. v. Commissioner , 98 T.C.
518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994). Petitioner resided in
Washington when he petitioned this Court.
In 1999 petitioner was employed as the president of Noll Manufacturing Co. (Noll). He remained preside…