Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 18 T.C. 892 (not yet in the library — opens the official source)
86 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    …tallment due July 15, 2017, to determine the net amount due as of that date ($22,500 − $7,608 = $14,892), and (3) adjusting the net amount to the valuation date of January 1, 2017 for the 6 1/2-month period between the valuation date and the due date for the required installment, using the effective interest rate for P…
  2. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008related by meaning
    ified retirement plan during 2002, before he had attained age 59-1/2 . Thus, even if the additional tax under section 72(t) is a "penalty, addition to tax, or additional amount" within the meaning of section 7491(c), a point we do not decide, there is ample evidence in the record to satisfy any burden of production imp…
  3. T.C. Memo. 2013-271 — Christine C. Peterson & Roger V. Peterson v. Commissioner
    IRCCourt RulingsNov 25, 2013
    …trustees. Mrs. Peterson received nonemployee compensation from Mary Kay of $750,127, $799,191, and $892,543 relating to 2006, 2007, and 2008, respectively. In 2009, Mrs. Peterson retired from Mary Kay and received nonemployee compensation pursuant to the FSP and the GFP agreements of $489,707. Petitioners timely filed …
  4. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  5. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …,603 $1,230,318 $1,009,373 $1,235,227 $889,174 Compensation of officers 176,300 274,600 451,200 437,892 239,200 Salaries & wages 49,649 74,655 37,767 52,014 53,296 Pension, profit-shar. plans 40,000 8,500 43,261 152,464 150,696 Employee benefit programs-0-100,000 56,739-0 - - 0 - Taxable income 69,279 478,098 95,100 23…
  6. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
  7. T.C. Memo. 2012-189 — James F. Drakes & Barbara E. Taylor v. Commissioner
    IRCCourt RulingsJul 11, 2012
    …tions are summarized as follows: -8Amount Amount Income claimed .determined . Wages (Ms. Taylor) $3,892 . $3,892 Wages (Mr. Drakes) 12,500 12,500 Totalincome 16,392 16,392 Amount Amount Expenses claimed determined Food, clothing, and miscellaneous $1,250 $1,633 Housing and utilities . 6,279 2,519 Vehicle operating cost…
  8. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    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 …
  9. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  10. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  11. 29 C.F.R. § 2570.4 — Parties.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  12. 80 FR 54374 — Determination of Minimum Required Pension Contributions
    IRCFinal Rules (FR)Sep 9, 2015
    e net amount due as of that date ($22,500 − $7,608 = $14,892), and (3) adjusting the net amount to the valuation date of January 1, 2017 for the 6 1/2 -month period between the valuation date and the due date for the required installment, using the effective interest rate for Plan C for 2017 ($14,892 ÷ 1.0590(6.5/12) =…
  13. T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont…
    IRCTreasury DecisionsSep 28, 2015
    …tallment due July 15, 2017, to determine the net amount due as of that date ($22,500 – $7,608 = $14,892), and (3) adjusting the net amount to the valuation date of January 1, 2017 for the 6%-month period between the valuation date and the due date for the required installment, using the effective interest rate for Plan…
  14. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her authority that would distinguish the Martin cases from the issue presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA - 25 - [*25] distributions is substantial in relation to the weight of the authorities sup…
  15. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    … appellate court, may raise the estoppel on its own motion in an appropriate case." In re Cassidy , 892 F.2d 637, 641 (7th Cir. 1990) (fn. ref. omitted) (citing Allen v. Zurich Ins. Co. , 667 F.2d 1162, 1168 n.5 (4th Cir. 1982)). The United States Court of Appeals for the Fifth Circuit acknowledged the right of appella…
  16. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …y productive. Olson v. United States, 292 U.S. 246, 255 (1934); Symington v. Commissioner, 87 T.C . 892, 897 (1986). The highest and best use is presumed to be the property’s current use absent proof to the contrary. Mountanos v. Commissioner, T.C. Memo. 2013-138, at *7, supplemented by T.C. Memo. 2014-38, aff’d , 651 …
  17. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  18. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … market does not exist typically for conservation easements. See Symington v. Commissioner, 87 T.C. 892, 895 (1986). C ourts usually value easements indirectly using a “before and after” approach, seeking to determine the reduction in property value attributable to the easement. See Treas. Reg. § 1.170A - 14(h)(3)(i ) …
  19. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  20. Notice 2026-32 — This notice provides that a broker-dealer that carries customer accounts and receives or holds funds or securities for those customers may, in lieu of demonstr…
    IRCNoticesJun 15, 2026
    …licability dates and propose new applicability dates relating to proposed regulations under section 892 of the Internal Revenue Code for determining whether an acquisition of debt by a foreign government is commercial activity and whether a foreign government has effective control of an entity. These proposed regulatio…