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75 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu…
    IRCRevenue RulingsDec 8, 2003related by meaning
    INCOME TAX Rev. Rul. 2003-122 Rev. Rul. 2003-122 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003. T.D. 9095 T.D. 9095 REG-136890-02 Final, temporar…
  2. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    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…
  3. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  4. 101 T.C. 70; 101 T.C. No. 5 — Cebula v. Commissioner
    IRCCourt RulingsJul 21, 1993
    Petitioner next argues that applying the 59% year age requirement in section 402(e)(4)(B) to all lump-sum distributions defined in section 402(e)(4)(A), as urged by the Commissioner, “renders portions of section 402(e)(4)(A) superfluous.” Petitioner contends that, under such an interpretation of section 402(e)(4)(B), “…
  5. T.C. Memo. 2004-287 — Michael J. Barkley v. Commissioner
    IRCCourt RulingsDec 28, 2004
    … a separate income tax on the distribution, using the special tax computation authorized by section 402(d)(1)(B) (hereinafter referred to as forward averaging). Under section 402(d)(1)(B), a distribution that qualifies as a lump-sum distribution eligible for forward averaging is taxed as if it were paid over 5 years ra…
  6. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
  7. Notice 2026-13 — Safe Harbor Explanations – Eligible Rollover Distributions
    IRCNoticesFeb 2, 2026
    …nt a recommendation from the U.S. Government Accountability Office (GAO). II. BACKGROUND A. Section 402(f) Section 402(f) requires the plan administrator of a plan qualified under section 401(a) to provide the written explanation described in section 402(f)(1) (section 402(f) notice) to any recipient of an eligible rol…
  8. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ion 572.  The burden is estimated as: (19,290 entities × 8 hours) = 154,320 hours. A labor rate of $133.05 is used for a computer programmer professional. The labor rate is applied in the following calculation: (19,290 entities × 8 hours) × $133.05 = $20,532,276. Back to Citation 573.  The burden is estimated as: (215 …
  9. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    …n the meaning of section 414(p), thus relieving petitioner of liability for tax pursuant to section 402(a)(9) on the $156,099.46 portion of the lump-sum distribution used to satisfy his mortgage and pay his ex-wife, and the $17,676 additional tax under section 72(t). For the reasons which follow, we hold that the Decre…
  10. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    …on references are to the Internal Revenue Code as amended and in effect for the year in issue. Sec. 402(a)(2) was amended by the Tax Reform Act of 1984, sec. 1001(b)(3) of Pub. L. 98-369, 98 Stat. 1011. This amendment was effective only for property acquired after June 22, 1984, and before Jan. 1, 1988, and is thus ina…
  11. 45 T.C. 133 — Jacobs v. Commissioner
    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 …
  12. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    …ing 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (1957), relied upon by petitioner, are clearly distinguishable on their facts.
  13. 85 FR 51369 — Rollover Rules for Qualified Plan Loan Offset Amounts
    IRCProposed Rules (FR)Proposed Aug 20, 2020
    …TCJA. On December 20, 2019, the Further Consolidated Appropriations Act of 2020, Public Law 116-94 (133 Stat. 2534) (the Act), was enacted. Section 114 of Division O of the Act, titled “Setting Every Community Up for Retirement Enhancement Act of 2019” (SECURE Act), amended section 401(a)(9) of the Code by changing the…
  14. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  15. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. 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)…
  16. 49 T.C. 419 — Gittens v. Commissioner
    IRCCourt RulingsJan 25, 1968related by meaning
    cases as applicable to section 402(a) (2), e.g., Jack E. Schlegel, supra; Rybacki v. Conley, 340 F. 2d 944 (C.A. 2, 1965); Thomas E. Judkins, 31 T.C. 1022 (1959); but it has been seriously questioned by others, e.g., United States v. Johnson, supra; United States v. Martin, supra; E. N. Funkhouser, supra. The “separati…
  17. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    …r decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-percent additional tax under section 72(t) on that distribution, (2) whether petitioner is liable for a 10-percent additional tax under section 72(t) on a portion of a …
  18. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    … occurring before August 29, 2005 . 'on supplemental brief respondent states that the amended sec . 402 ( a) regulations are inapplicable to this case to the extent that they changed the,law effective as of , Aug . 29, 2005 . Respondent states : Respondent notes that whether the transfer was or was not a distribution f…
  19. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
  20. 76 T.C. 499; 2 Employee Benefits Cas. (BNA) 1145 — Fujinon Optical, Inc. v. Commissioner
    IRCCourt RulingsMar 31, 1981related by meaning
    taken into account in applying these tests. * * * [H. Rept. 93-807, supra, 1974r-3 C.B. (Supp.) at 285; S. Rept. 93-383, supra, 122. Emphasis added.] Thus, both the statute and the legislative history explaining it clearly indicate that all of the employees of a controlled group are to be considered, without limitatio…