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79 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 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
    INCOME TAX Notice 2006-76 Notice 2006-76 This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
  2. 79 FR 61440 — Liquidity Coverage Ratio: Liquidity Risk Measurement Standards
    IRCFinal Rules (FR)Oct 10, 2014
    …ay 8 10 175 8 143 32 Day 9 15 190 7 150 40 Day 10 25 215 20 170 45 Day 11 35 250 5 175 75 Day 12 10 260 15 190 70 Day 13 0 260 0 190 70 Day 14 0 260 0 190 70 Day 15 5 265 5 195 70 Day 16 15 280 5 200 80 Day 17 5 285 5 205 80 Day 18 10 295 5 210 85 Day 19 15 310 20 230 80 Day 20 0 310 0 230 80 Day 21 0 310 0 230 80 Day …
  3. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
  4. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    t it was final and conclusive and not to be reopened except “upon a showing of fraud or malfeasance or a wilful misrepresentation of a material fact.” In view of the foregoing we conclude that the separate identity of the petitioner and the other two corporations must be recognized in these rebate proceedings. Section …
  5. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    IRCCourt RulingsJun 6, 2005related by meaning
    a matter of legislative grace, and the burden of clearly showing the right to the claimed deduction is on the taxpayer. INDOPCO, Inc. v. Commissioner , 503 U.S. 79, 84 (1992). We are bound by the Internal Revenue Code, and it is within the province of the legislature to decide the circumstances of inclusion, deductions…
  6. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
  7. I.R.C. § 72(d)(1)(B)(iii) — Annuities; certain proceeds of endowment and life insurance contracts
    IRCCode / StatuteJan 6, 2025
    …ts is: Not more than 55 360 More than 55 but not more than 60 310 More than 60 but not more than 65 260 More than 65 but not more than 70 210 More than 70 160. (d)(1)(B)(iv) (iv) Number of anticipated payments where more than one life If the annuity is payable over the lives of more than 1 individual, the number of ant…
  8. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
  9. Treas. Reg. § 1.72-5(b)(2) — Expected return.
    IRCRegulationsJul 26, 2016
    … respect to this portion of the annuity contract of $9,120 ($1,200 × 7.6). An expected return of $7,260 ($600 × 12.1) would be obtained with respect to the payments to be made to the husband, yielding a total expected return under the contract of $16,380 ($9,120 plus $7,260). If payments are to be made quarterly, semia…
  10. 29 T.C. 632 — General Retail Corp. v. Commissioner
    IRCCourt RulingsDec 31, 1957related by meaning
    y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
  11. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    …08 .363 .411 .459 .507 .555 54 .069 .135 .197 .256 .313 .369 .418 .467 .516 .565 55 .070 .137 .200 .260 .318 .375 .425 .475 .525 .575 56 .072 .141 .206 .268 .328 .387 .439 .491 .543 57 .074 .145 .212 .27
  12. T.C. Summary Opinion 2001-60 — Blaney H. Howle, III & Polly T. Howle v. Commissioner
    IRCCourt RulingsApr 23, 2001
    … Howle’s total employee contributions are $20,365.56. The number of anticipated monthly payments is 260. See sec. 72(d)(1)(B). Thus, petitioners may exclude $156.66 ($20,365.56 divided by 260 and multiplied by 2) of their Tier 2 benefits. See id. Because Mrs. Howle had no employee contributions, all of her Tier 2 benef…
  13. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  14. T.C. Memo. 2008-285 — Jacob & Fern Jankelovits v. Commissioner
    IRCCourt RulingsDec 22, 2008
    …ntaxable transfer of the Unibank IRA, and on that date Mrs . Jankelovits was issued a check for $39,260, representing the balance of the Unibank IRA . Mrs . Jankelovits deposited the check in the Washington Mutual account . Thereafter, up until the time of trial, petitioners did not withdraw any funds from the Washingt…
  15. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    f proof in this case is affected by the fact that we carefully scrutinize transactions between related parties, Maxwell v. Commissioner , 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner , 49 T.C. 649, 656 (1968), remanded pursuant to stipulation of the parties 406 F.2d 290 (6th Cir. 1969), and that…
  16. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    … 401-K Plan 45,000 45,000 - Condo 185,000-185,000 Industrial Bldg. 107,500-107,500 Industrial Bldg. 260,000-260,000 Industrial Vacant 65,000 65,000 - Stock - HSSTC 59,200 59,200 - Prestige 23,500-23,500 Breck 25,000 25,000 - West Coast 25,000 25,000 - Sunshine 20,910 20,910 - FSCC 5,000 5,000 - Sailboat 85,000 85,000 -…
  17. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    tribution with respect to an employee under subparagraph (A) only if— (i) such amount is received on or after the employee has attained age 591/2, and (ii) the taxpayer elects for the taxable year to have all such amounts received during such taxable year so treated. Not more than 1 election may be made under this subp…
  18. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    T.C. Memo. 2004-260 042 UNITED STATES TAX COURT JOSEPH R. ROLLINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 598-03. Filed November 15, 2004. P caused the 401(k) plan of his wholly owned company to lend money to three entities in which P owned minority interests. P's company is the sole trus…
  19. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    tment in a building” under § 216(b)(1)(B). (45) Section 264.—Certain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(d)(1) applies. (46) Section 264(c)(1).—Contracts Treated as Single Premium Contracts.—Whether “substantially all” the premiums of a contract of insurance are paid within a period of 4 …
  20. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …tes initiated—90 percent (2,340,000) disputes initiated against the top 10 non-initiating parties = 260,000 disputes initiated against other non-initiating parties. 260,000 disputes/1,575 issuers/TPAs = 165 disputes per issuer/TPA annually. 165 disputes × $77.97 per dispute = $12,865 per small issuer/TPA. Back to Citat…