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76 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
  2. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …ociated with new QPAMs meeting the policies and procedures requirements of the QPAM Exemption is $1,663.[77] QPAM-Sponsored Plans—Independent Audit—Section V(c)
  3. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    … question of fact to be resolved on the basis of the entire record. Kaplan v. Commissioner, 43 T.C. 663, 665 (1965). To support their positions regarding valuation, the parties retained experts. We assess an expert ’ s opinion in the light of the expert’s qualifications and the evidence in the record. See Parker v. Com…
  5. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …articipating provider at a participating facility,[185] the Departments estimate that approximately 663,436 individuals will have the potential to be treated by a nonparticipating provider or facility. In the absence of data, the Departments assume that in 50 percent of cases services will be provided by nonparticipati…
  6. Treas. Reg. § 1.404(a)-12(b)(3) — Contributions of an employer under a plan that does not meet the requirements of section 401(a); application of section 404(a)(5).
    IRCRegulationsMay 18, 2016
    … accounts must be sufficiently separate and independent to qualify as separate shares under section 663(c). Nothing shall preclude a trust which loses its exemption under section 501(a) from setting up such acounts and meeting the separate account requirement of section 404(a)(5) with respect to the taxable years in wh…
  7. Treas. Reg. § 1.436-1(g)(6) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …lication of the restriction on plan amendments under paragraph (c) of this section. Therefore, $105,663 (that is, the $196,048 actual contribution paid on February 1, 2011, minus the $90,385 required contribution based on the actual AFTAP) is recharacterized as an employer contribution under section 430 for the 2011 pl…
  8. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …Table 16—General Data Description Assumption Source Number of Small Defined Contribution (DC) Plans 663,107 2022 Form 5500 Data. Number of Small Defined Benefit (DB) Plans 40,117 2022 Form 5500 Data. All Participants in Small Plans 14,588,887 2022 Form 5500 Data. Service Providers for Accounting, Actuarial Services, an…
  9. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …S.C. § 1132(g)(1) (emphasis added); see also Plasterers’ Loc. Union No. 96 Pension Plan v. Pepper , 663 F.3d 210, 221– 22 (4th Cir. 2011) . Kelly also argues the district court failed to properly apply the Quesinberry factors and failed to consider the remedial purposes of ERISA and its fee analysis . But we find the d…
  10. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …S.C. § 1132(g)(1) (emphasis added); see also Plasterers’ Loc. Union No. 96 Pension Plan v. Pepper , 663 F.3d 210, 221– 22 (4th Cir. 2011) . Kelly also argues the district court failed to properly apply the Quesinberry factors and failed to consider the remedial purposes of ERISA and its fee analysis . But we find the d…
  11. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    …of 7.00%. Ex. C36. 13Interest that had accrued to January 1, 1988 on these CDS in the amount of $42,663.10 was deposited in the Plan's account on January 20, 1988. Ex. C18. CD No. 11813-17735 was outstanding from January 1, 1988 to May 18, 1988 at an annual interest rate of 6.65%. Ex. C15. 14CD No. 11813-17916 was outs…
  12. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  13. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …evant items: 2001 2002 2003 Compensation of officers $379,000 $411,400 $500,000 108 213 125,266 138,663 Salaries and wages Pension, profit-sharing, 27 299 22,731 21,789 etc., plans - 8 - Employee benefit programs -- --t - Consultant fees 99,000 90,453 101,000 For the years at issue Diogenes reported the following relev…
  14. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  15. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
  16. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987related by meaning
    alty was designed to cover the situation involved herein. Because of such doubt, we think it judicious to resolve this issue in favor of the taxpayer. Finally, we must decide whether additions to tax pursuant to section 6653(a)(1) and (a)(2) should be imposed. Section 6653(a)(1) provides for an addition to tax of 5 per…
  17. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025
    …r establishes that some 27 [* 27] portion of the underpayment is not attributable to fraud. See § 6 663(a) and (b); Sadler v. Commissioner, 113 T.C. 99, 105 (1999). We find that r espondent has established by clear and convincing evidence that Mr. Hutcheson had $5,307,68 8 in unreported embezzlement income for 2010 and…
  18. 78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Jul 2, 2013
    …cumstance not presented here. See Cohen, J., et al., New England Journal of Medicine. 2008, 358:661-663 (February 14, 2008) http://www.nejm.org/​toc/​nejm/​358/​7; CBO Letter to Congressman Nathan Deal, (August 7, 2009).
  19. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012
    …A (the accuracy related penalty on understatements with respect to reportable transactions) of $875,663.04. One document, Form 4549, Income Tax Examination Changes, detailed the adjustments made to petitioner's income tax return. Form 4549 recalculated petitioner's income, his expenses reported on Schedule C, Profit or…
  20. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    ntentional disregard of rules and regulations." Additionally, they make no argument on brief concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have conceded the additions to tax pursuant to section 6653. Petitioners and the corporation argue that, to t…