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82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  2. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    ust decide (1) whether section 4979A(a) imposes an excise tax on petitioner for its taxable year 2005 and (2) if so, whether the period of limitations under section 4979A(e)(2)(D) has expired for assessing that tax for that year. We turn first to whether section 4979A(a) imposes an excise tax on petitioner for its taxa…
  3. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  4. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    begin with section 4973. Section 4973 Section 4973(a) imposes a 6-percent excise tax on excess contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as a deduction under section 219 (computed without regard to section - 27 - 219(g)), exclusive of amounts p…
  5. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  6. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    en the IRA in question constituted an "excess contribution” and not just a portion of the transfer, as herein. See also Benbow v. Commissioner, supra. Congress has provided other sanctions for the misuse of IRA’s. In particular, section 4973 imposes an annual excise tax of 6 percent of the amount of the excess contribu…
  7. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …ALTH PLANS Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
  8. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  9. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    … 0.435 0.475 46 .061 .119 .173 .224 .273 .321 .362 .403 .444 .485 47 .062 .121 .176 .228 .278 .327 .369 .411 .453 .495 48 .063 .123 .179 .232 .283 .333 .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…
  10. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
  11. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    the deduction would frustrate a sharply defined Federal or State policy. Wood v. United States , 863 F.2d 417 (5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir. 1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v. Commissioner , 69 T.C. 114 (1977). The test of nondeductibility is the severity and imme…
  12. T.C. Memo. 2008-17 — Herbert & Christine Bangs v. Commissioner
    IRCCourt RulingsJan 31, 2008
    …ief, however, respondent agrees position . 13DEFRA also amended sec . 215 (amended s e Pub . L . 98-369, sec . 422(b), 98 Stat . 797 . T applies with respect to (1) divorce and separ ction 71 as amended Pub . L . 98-369 , Responden t to those payments . . In any event, w e ifts to respondent n of the issue burden of pr…
  13. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002related by meaning
    es on private income having its source in the receiving State and capital taxes on investments made in commercial undertakings in the receiving State; Similarly, article 49(d) of the Vienna Convention on Consular Relations (article 49), 21 U.S.T. at 108, provides that consular officers and employees are exempt from all…
  14. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  15. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    T.C. Memo. 1999-369 UNITED STATES TAX COURT WESTCHESTER PLASTIC SURGICAL ASSOCIATES, P.C., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13073-97R. Filed November 5, 1999. Andrew I. Panken and Robert A. DeVellis , for petitioner. Mark L. Hulse and Catherine R. Chastanet , for respondent. MEMORA…
  16. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…
  17. 137 T.C. No. 2 — Robert K. & Joan L. Paschall v. Commissioner
    IRCCourt RulingsJul 5, 2011
    …liance on the erroneous advice of an IRS office or employee. McMahan v. Commissioner, 114 F.3d 366, 369 (2d Cir. 1997), affg. T.C. Memo. 1995-547; see also Gagliardi v. Commissioner, T.C. Memo. 2008-10. Reliance on a mistaken legal opinion of a competent tax adviser that it was unnecessary to file a return also constit…
  18. 88 FR 11793 — Annual Reporting and Disclosure
    ERISAFinal Rules (FR)Feb 24, 2023
    employers, it is estimated that a total of 3,369 small participating plans and 842 large participating plans would provide benefits through PEPs.[38] The DOL assumes this would result in a direct decrease of 3,369 defined contribution Form 5500-SF filers and a decrease of 563 Form 5500 defined contribution filers. As …
  19. 82 FR 7336 — Proposed Best Interest Contract Exemption for Insurance Intermediaries
    ERISAProposed Rules (FR)Proposed Jan 19, 2017
    …equency of Response: When engaging in exempted transaction. Estimated Total Annual Burden Hours: 69,369 during the first year and 66,037 annually in subsequent years; includes 8,389 during the first year and 5,057 annually in subsequent years of duplicative burden that will be transferred over from OMB Control Number 1…
  20. T.D. 9223 — Final regulations under section 402 of the Code address the amount includible in a distributee’s income when life insurance contracts are distributed by a qual…
    IRCTreasury DecisionsSep 26, 2005related by meaning
    also be used to furnish the donor of a qualified vehicle with a contemporaneous written acknowledgment. EXCISE TAX Rev. Rul. 2005-64 Rev. Rul. 2005-64 Interaction of sections 469 and 4261. This ruling describes the circumstances in which losses incurred by an individual who provides air transportation through a passthr…