Search the Pension Law Library

21. 82 FR 46388 — Mortality Tables for Determining Present Value Under Defined Benefit Pension Plans
    IRCFinal Rules (FR)Oct 5, 2017
    …4,356 million Estimated change in PBGC premiums (in millions of 2017 dollars) Full take-up amount 0 293 287 187 91 0 0 0 0 81 No take-up amount 293 287 280 183 89 0 0 0 0 80 Present Value with full take-up of delay option (3% Discount Rate): 869 million Present Value with no take-up of delay option (3% Discount Rate): …
22. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
23. Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o…
    IRCRevenue RulingsSep 8, 2014
    …he requirements of Rev. Rul. 2011–1, 2011–2 I.R.B. 251, as modified by Notice 2012–6, 2012–3 I.R.B. 293, to include trusts of certain retirement plans qualified only under the Puerto Rico Code (Código de Rentas Internas para un Nuevo Puerto Rico de la Ley Núm. 1 de 31 de enero de 2011) and clarifies that assets held by…
24. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
25. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … cause defense is not available. See § 6664(c)(3); see also Chandler v. Commissioner, 142 T.C. 279, 293 (2014). B. Constitutional Challenge to Section 6662 Penalty Petitioner disputes the constitutionality of the accuracy-related penalty under section 6662 in the light of the U.S. Supreme Court’s decision in SEC v. Jar…
26. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
27. PLR 201650003 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsDec 9, 2016
    …modified by Rev. Rul. 2011-1, 2011-2 I.R.B. 251 (which was modified by Notice 2012-6, 2012-3 I.R.B. 293) (an “81-100 group trust”). The ruling specifi es that Taxpayer is exempt from federal income tax (i) under Internal Revenue Code (“Code”) section 501(a) for the funds that equitably belong to its participating trust…
28. 29 C.F.R. § 4907.112-4907.129 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
29. 81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    nancial institution, an insurance company, or a broker-dealer. Back to Citation 8.  Cerulli Associates, “Retirement Markets 2015.” Back to Citation 9.  The Department initially proposed an amendment to its regulation defining a fiduciary within the meaning of ERISA section 3(21)(A)(ii) and Code section 4975(e)(3)(B) on…
30. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023★ strong match
    …lerical or mathematical error. Raquet v. Commissioner, T.C. Memo. 1996-279, 1996 Tax Ct. Memo LEXIS 293 , at *10 . The taxpayer retain s the burden with regard to the Commissioner’s determinations. I d . at *10 – 11 ( first citing Estate of Applestein v. Commissioner, 80 T.C. 331, 347 n.5 (1983); then citing Beck Chem.…
31. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    …33 .376 .419 .462 .505 49 .064 .125 .182 .236 .288 .339 .383 .427 .471 .515 50 .065 .127 .185 .240 .293 .345 .390 .435 .480 .525 51 .066 .129 .188 .244 .298 .351 .397 .443 .489 .535 52 .067 .131 .191 .248 .303 .357 .404 .451 .498 .545 53 .068 .133 .194 .252 .308 .363 .411 .459 .507 .555 54 .069 .135 .197 .256 .313 .369…
32. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent. Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
33. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …ith Requirements) 217,651 158,885 58,766 114,271 Self-insured (States without Requirements) 401,392 293,016 108,376 210,739 Fully insured (States without Requirements) 314,761 229,775 84,985 165,256 Total Private 933,803 681,677 252,127 490,266 All Plans 995,792 726,928 268,864 522,811 * Totals displayed in the table m…
34. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
35. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …tes v. American Trucking Associations, Inc. , supra at 542; Helvering v. Stockholms Enskilda Bank , 293 U.S. 84, 93-94
36. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963related by meaning
    422, 441. Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
37. PLR 202524006 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsJun 13, 2025
    …fied and modified by Rev. Rul. 2004-67, 2004-2 CB 28, Rev. Rul. 2011 - 1, Notice 2012-6, 2012-3 IRB 293, and Rev. Rul. 2014-24, 2014-37 IRB 529. Rev. Rul. 81-100 is itself a restatement of the rules governing group trusts under Rev. Rul. 75-530, 1975-2 CB 146, and Rev. Rul. 56-267, 1956-1 CB 206. PLR - 115585-24 4 Rev.…
38. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
39. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    ” —not ours. See United 44 States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
40. PLR 202417010 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsApr 26, 2024
    …fied and modified by Rev. Rul. 2004-67, 2004-2 CB 28; Rev. Rul. 2011 - 1; Notice 2012-6, 2012-3 IRB 293; and Rev. Rul. 2014-24, 2014-37 IRB 529. Rev. Rul. 81-100 is itself a restatement of the rules governing group trusts under Rev. Rul. 75-530, 1975-2 CB 146, and Rev. Rul. PLR - 115761-23 3 56-267, 1956-1 CB 206. inco…