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…
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…
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…
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), “…
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…
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 …
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…
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 …
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…
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…
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 …
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.
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…
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…
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)…
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…
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 …
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…
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., …
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…