ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJul 31, 2000related by meaning
he insured died. Petitioners
observe that the employee/owners’ ability to withdraw the
conversion credit balance was limited to the percentage of that balance that was transferred to the C-group conversion UL policy.
Petitioners observe that the transferred credits could be reached
by an insured only if a C-group term …
Rev. Rul. 2004-65 — Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of … IRCRevenue RulingsJul 6, 2004related by meaning
INCOME TAX
Rev. Rul. 2004-63 Rev. Rul. 2004-63
Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.
Rev. Rul. 2004-66 Rev. Rul. 2004-66
Fede…
IRCCourt RulingsApr 11, 2012related by meaning
t exceeds the investment in the contract. Sec. 72(e)(1)(A), (5)(A),
(C), (E)(ii). The investment in the contract is defined génerally as the aggregate amount of premiums or other consideration paid for the contract less amounts
previously received under the contract, to the extent such latter amounts were
excludable fr…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…mployee’s spouse or dependent. See paragraph (q) in §1.125-1 for nonqualified benefits. (l) Section 105(h) requirements. Section 105(h) applies to health FSAs. Section 105(h) provides that the exclusion provided by section 105(b) is not available with respect to certain amounts received by a highly compensated individu…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
IRCCourt RulingsJul 13, 1995related by meaning
…ns. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance), affd. 755 F.2d 790 (11th Cir. 1985).
We have cons…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
rom the proceeds of the life insurance contract. See generally Cadwell
v. Commissioner, 136 T.C. 38, 63-64 (2011), aff'd, 483 Fed. Appx. 847 (4th Cir. 2012). Section 1.61-22, Income Tax Regs., is effective for split-dollar life
insurance arrangements entered into after September 17, 2003, and an arrangement
that is "ma…
IRCCourt RulingsFeb 26, 1964
…ners from the special fund are not excludable from gross income under either section 104 or section 105 unless they are covered by subsection 105(b), subsection 105(c), or subsection 105(d). Only the last subsection (105(d)), to which petitioners make no reference in their argument, can have any possible application to…
IRCCourt RulingsJun 6, 2005related by meaning
a matter of
legislative grace, and the burden of clearly showing the right to
the claimed deduction is on the taxpayer. INDOPCO, Inc. v.
Commissioner , 503 U.S. 79, 84 (1992). We are bound by the
Internal Revenue Code, and it is within the province of the
legislature to decide the circumstances of inclusion, deductions…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
tment in a building” under § 216(b)(1)(B).
(45) Section 264.—Certain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(d)(1) applies. (46) Section 264(c)(1).—Contracts Treated as Single Premium Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
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 …
IRCPrivate Letter RulingsNov 14, 2008
…) of the taxpayer, his spouse, and his dependents (as defined in section 15 2 of the Code).
Section 105(h) of the Code generally provides that amounts paid to highly
compensated individuals under a discriminatory self-insured medical expense
reimbursement plan are not excludable from gross income under section 105(b) t…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100…
85 FR 59132 — Pension Benefit Statements-Lifetime Income Illustrations ERISAFinal Rules (FR)Sep 18, 2020
…citation for part 2520 continues to read as follows:
Authority:
29 U.S.C. 1021-1025, 1027, 1029-31, 1059, 1134 and 1135; and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Sec. 2520.101-2 also issued under 29 U.S.C. 1132, 1181-1183, 1181 note, 1185, 1185a-b, 1191, and 1191a-c. Secs. 2520.102-3, 2520.104b…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMar 17, 1987
) (relating to medical care benefits), sections 105(b) and 105(c) are analogous in the context of this case.
The ruling suggests the following points: (1) Amounts contributed by an employer out of its profits represent deferred compensation for services rendered by the employee and are taxable to him as provided in sec…
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
…e written description for small and large entities, respectively. This results in an hour burden of 260,967 hours with an equivalent cost of $43,244,858 in the first year.[86]
Table 6—Hour Burden and Equivalent Cost Associated With the All Material Facts
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden c…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …