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96 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. IRCRegulationsMay 18, 2016
    … held in the account are invested in stock of a regulated investment company (as defined in section 851(a) relating to mutual funds); (d)(2)(ii) (ii) The requirements of § 1.403(b)-6(c) (imposing restrictions on distributions with respect to a custodial account) are satisfied with respect to the amounts held in the acc…
  2. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
  3. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010
    …1982), an d Phillips v . Commissioner , 86 T .C . 433, 441 n . :7 : (1986), affd . as to this issue 851 F .2d 1492 (D .C : Cir . .1988))` . 16
  4. Treas. Reg. § 1.411(b)(5)-1(d)(5)(iv) — Reduction in rate of benefit accrual under a defined benefit plan.
    IRCRegulationsSep 17, 2024
    …if it is equal to the rate of return on a regulated investment company (RIC), as defined in section 851, that is reasonably expected to be not significantly more volatile than the broad United States equities market or a similarly broad international equities market. For example, a RIC that has most of its assets inves…
  5. 29 C.F.R. § 2570.163 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  6. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024
    …defined as any domestic corporation other than a regulated investment company (“RIC”) under section 851, a real estate investment trust (“REIT”) under section 856, or an S corporation under section 1361, as a non-look-through person. Proposed § 1.897-1(c)(3)(v)(A) and (D). However, the proposed regulations treated non-…
  7. 29 C.F.R. § 2520.104-23(a) — Alternative method of compliance for pension plans for certain selected employees.
    ERISARegulationsAug 16, 2019
    …ployees, pursuant to the authority of the Secretary of Labor under section 110 of the Act (88 Stat. 851). (a)(2) (2) Under section 110 of the Act, the Secretary is authorized to prescribe an alternative method for satisfying any requirement of part 1 of title I of the Act with respect to any pension plans, or class of …
  8. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
  9. Notice 2025-68 — Notice of intent to issue regulations with respect to section 530A Trump accounts
    IRCNoticesDec 22, 2025
    … ETF must be a domestic corporation (including a regulated investment company as defined in section 851(a)) for Federal income tax purposes that meets the additional requirements to be a mutual fund or ETF in the following paragraphs. For purposes of section 530A(b)(3), a mutual fund must be registered under the Invest…
  10. PLR 201001016 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJan 8, 2010
    …itted to hold will not be limited to regulated investment compa nies (RICs) within the meaning of § 851 managed by IC or any of its affiliates. IC will not impose any significant barriers to reallocations between and among eligible assets within the Account. IC may require automatic rebalancing of the Account to brin g…
  11. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  12. PLR 200949007 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 4, 2009
    …be permitted to hold will not be limited to regulated investment companies, within the meaning of § 851, managed by IC or any of its affiliates. IC will not impose any significant barriers to reallocations between and among eligible assets within the Account. IC may require automatic rebalancing of the Account to bring…
  13. PLR 200949036 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 4, 2009
    …be permitted to hold will not be limited to regulated investment companies, within the meaning of § 851, managed by Taxpayer or any of its affiliates. Taxpayer will not impose any significant barriers to reallocations between and among eligible assets within the Account. Taxpayer may require automatic rebalancing of th…
  14. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  15. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010
    …( 1963 ), affd . .334 F .2d 351 ( 8th Cir . 1964 ) ; Waldheim v . Commissioner , 25 T .C . 839, 850-851 (1956),
  16. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …e sec. 6751(b)(1); Graev v. Commissioner, 149 T.C. 485, 492-94 (2017) (citing Chai v. Commissioner, 851 F.3d 190, 221 (2d Cir. 2017), aff'g in part, rev'g in part T.C. Memo. 2015-42), supplementing and overruling in part 147 T.C. 460 (2016). - 21 - [*21] under section 404. The Commissioner argues that Burbach's "direct…
  17. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  18. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
  19. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …ust if it is "clothed with the characteristics of a trust"); Hart v. Commissioner, 54 F.2d 848, 850-851 (1st Cir. 1932), rev'g in part 21 B.T.A. 1001 (1930); Johnson v. Commissioner, 108 T.C. 448, 475 (1997), aff'd in part, rev'd in part on other grounds, 184 F.3d 786 (8th Cir. 1999); George Gleason Bogert, et al., Bog…
  20. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…