IRCCourt RulingsJan 20, 1983related by meaning
… actual funding and actual disallowance of deductions are not issues of qualification under section 401(a), respondent contends that the rules set forth in section 1.415-5, Income Tax Regs., further the original intent of Congress, as confirmed by TEFRA, in prohibiting premature application of the annual cost-of-living…
IRCCourt RulingsJul 25, 1984related by meaning
… that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining whether a partial termination has occurred. H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 300; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80, 129.
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
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
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsMay 22, 2025
…’s expert testimony on the basis of
his failure to include certain publications as required by Rule 143(g)(1)(D). While we
do not condone omission of these particular documents , w e find that the failure did not
unduly prejudice respondent. Our sense at trial was that Dr. Reichert did not intend
to violate t he spirit…
IRCCourt RulingsMar 31, 1981related by meaning
… employees of a controlled group are to be considered, without limitation, for purposes of sections 401(a) and 410(b)(1). The abuse example contained in the Senate and House reports does not, in the absence of more specific statutory direction, provide adequate justification for conditioning employee aggregation upon a…
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 …
IRCCourt RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
IRCCourt RulingsFeb 24, 2011
…as let go
from his job, and he defaulted on the loan, at which time the
outstanding balance was $29,143.
Petitioner and her husband filed a joint Federal income tax
return for 2007. On the return, petitioner did not report the
defaulted loan of $29,143 from her husband's 401(k).
Petitioner attached to her joint return …
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsAug 30, 1993related by meaning
…to tax
Year endedDeficiencySec. 6651(a)(1)Sec. 6651(a)(2)
FYE 1985$ 340$ 76.50$ 85
FYE 19871,624365.401
The*55 above deficiencies result from respondent's determinations that petitioner's defined benefit pension plan (pension plan) had a $ 6,800 accumulated funding deficiency within the meaning of section 412 in FYE 19…
IRCCourt RulingsNov 26, 2014
143 T.C. No. 21
UNITED STATES TAX COURT
RSW ENTERPRISES, INC., Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
KEY LIME INVESTMENTS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 14820-11R, 14821-11R. Filed November 26, 2014.
Ps, domestic corporations, each established a retire…
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
…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 contributions to defined benefit plans and permitted disparity.
EXEMPT ORGANIZATIONS
T.D. 9130 — Final regulations concern required minimum distributions under section 401(a)(9) of the Code for defined benefit plans and annuity contracts providing benefits… IRCTreasury DecisionsJun 28, 2004
…NCOME TAXES Paragraph 1. The authority citation for part 1 is amended by removing the entry for “§1.401(a)(9)-6T” and adding an entry in numerical order to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
§1.401(a)(9)-6 is also issued under 26 U.S.C. 401(a)(9). * * *
Par. 2. Remove “§1.401(a)(9)-6T” and repla…
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…
85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAFinal Rules (FR)May 27, 2020
…a website.)
Back to Citation
110.
According to Private Pension Plan Bulletin 2017, there were over 143,000 defined benefit plans and nonparticipant-directed defined contribution plans. Applying an assumption of 18 percent, the Department estimates approximately 25,984 (143,558 * 0.181) plans currently lack websites. T…
84 FR 60812 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions IRCProposed Rules (FR)Proposed Nov 8, 2019
…ority citation for part 1 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *
§ 1.401(a)(9)-5 [Amended]
Par. 2.
Section 1.401(a)(9)-5 is amended by:
1. Removing the language “A-1 of § 1.401(a)(9)-9” wherever it appears and adding “§ 1.401(a)(9)-9(b)” in its place.
2. Removing the language “A-2 of § 1.…
IRCCourt RulingsSep 13, 1990related by meaning
…89 OPINION
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $ 143,327.
The issue for decision is whether section 403(e)(3) of the Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 305 (ERTA), precludes petitioner from qualifying for an unlimited marital deduction under sec…
IRCCourt RulingsNov 28, 1967related by meaning
…hat he bases his contention that the $15,000 was entitled to capital gains treatment under sections 401 and 402, I.R.C. 1954. These statutes are not applicable. In general, section 401 sets forth the requirements for qualification of an employees’ trust or pension plan so that contributions of the employer to the trust…
85 FR 72472 — Updated Life Expectancy and Distribution Period Tables Used for Purposes of Determining Minimum Required Distributions IRCFinal Rules (FR)Nov 12, 2020
ction 1.401(a)(9)-5 is amended by:
1. Removing the language “A-1 of § 1.401(a)(9)-9” wherever it appears and adding “§ 1.401(a)(9)-9(b)” in its place. 2. Removing the language “A-2 of § 1.401(a)(9)-9” wherever it appears and adding “§ 1.401(a)(9)-9(c)” in its place.
3. Removing the language “A-3 of § 1.401(a)(9)-9” whe…