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72 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
  3. 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 …
  4. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  5. 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 …
  6. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
    IRCTreasury DecisionsSep 18, 2006related by meaning
    nder section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. ADMINISTRATIVE Rev. Proc. 2006-34 Rev. Proc. 2006-34 This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure …
  7. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002
    …ms in income and claimed deductions to which he was not entitled. Higbee v. Commissioner , 116 T.C. 438, 442 (2001). records of his purported IRA contribution nor did he demonstrate that he maintained such records. The same may be said regarding any IRA that Mrs. Kirshenbaum may have maintained. We conclude that petiti…
  8. 78 FR 53704 — Employee Retirement Benefit Plan Returns Required on Magnetic Media
    IRCProposed Rules (FR)Proposed Aug 30, 2013related by meaning
    ublic hearing is scheduled, notice of the date, time, and place of the public hearing will be published in the Federal Register . Drafting Information The principal authors of these regulations are William Gibbs and Pamela R. Kinard, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities…
  9. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    and monthly net income to be $8,663, $8,225, and $438, respectively. On the basis of petitioners' net realizable equity of $19,342.80 and monthly net income of $438 over 110 months, the COIC Unit determined that petitioners could fully satisfy their tax liability, which then totaled $46,657.77. The COIC Unit then tran…
  10. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
  11. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …s if it actually engaged in business activity. See Moline Props., Inc. v. Commissioner, 319 U.S. at 438-439; Bass v. Commissioner, supra at 602. The prongs of the test under Moline Props. are alternative prongs. See Moline Props., Inc. v. Commissioner, supra at 438-439; Bass v. Commissioner, supra at 602; see also Roge…
  12. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    …ements. Pursuant to these agreements the Summa subsidiaries paid JC Export $129,791, $672,048, $625,438, and $810,646 on January 18, April 23, July 25, - 7 - [*7] and December 22, 2008, respectively.5 Summa also paid $1,083 of expenses on behalf of JC Export and JC Holding during 2008. The Summa subsidiaries paid JC Ex…
  13. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law…
  14. 20 C.F.R. § 901.12(f)(1)(iii) — Eligibility for enrollment.
    Joint BoardRegulationsOct 18, 2016related by meaning
    (f)(1)(iii) (iii) Willfully failing to make a Federal tax return in violation of the revenue laws of the United States, or evading, attempting to evade, or participating in any way in evading or attempting to evade any federal tax or payment thereof, knowingly counseling or suggesting to a client or prospective client …
  15. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
  16. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
  17. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972
    …ions, First National forwarded to petitioner by letter on May 13, 1966, a check in the amount of $2,438.18, payable to petitioner, which letter 'and check were received by petitioner in due course through the mails. Making distribution to petitioner was not only in violation of petitioner’s request and direction, but a…
  18. Joint BoardRegulationsDec 30, 2016related by meaning
    (b) (b) Depositions upon oral examination (b)(1) (1) A deposition must be taken before an officer duly authorized to administer an oath for general purposes or before an officer or employee of the Internal Revenue Service who is authorized to administer an oath in Federal tax law matters. (b)(2) (2) In ordering a depos…
  19. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
  20. 76 FR 69126 — Graduated Retained Interests
    IRCFinal Rules (FR)Nov 8, 2011related by meaning
    sthroughs and Special Industries), IRS. List of Subjects in 26 CFR Part 20 Estate taxes Reporting and recordkeeping requirements ( printed page 69128) Adoption of Amendments to the Regulations Accordingly, 26 CFR part 20 is amended as follows: PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Paragra…