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94 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …rs + 130 TPAs) = $16.98. Back to Citation 108.  The annual cost for issuers is estimated as: $1,192,641 × 0.5 × 0.2% = $1,193. The annual cost for small physicians is estimated as: $1,192,641 × 0.5 × 36.8% = $219,446. Back to Citation 109.  The annual per-claim cost for issuers is estimated as: $1,193/125 Issuers = $9.…
  2. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  3. 85 FR 66219 — Effect of Section 67(g) on Trusts and Estates
    IRCFinal Rules (FR)Oct 19, 2020
    One commenter noted that, under §  1.641(c)-1(j), if an electing small business trust (ESBT) election terminates or is revoked and the S portion has a net operating loss or capital loss carryover or deductions in excess of gross income, then any such loss, carryover or excess deductions are allowed as a deduction, in a…
  4. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    nership’s activities lacked economic substance. The taxpayer has now offered to compromise all the penalties and interest on terms more favorable than those contained in the prior settlement offer, arguing that TEFRA is unfair and that the liabilities accrued in large part due to the actions of the Tax Matters Partner …
  5. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …ion 18,113,320 paper statements = 464,444,095 DC Statements × 3.9% delivered by paper 5 1  $1.25 22,641,650 DB Statement Distribution 339,403 paper statements = 8,702,640 non-frozen DB Statements × 3.9% delivered by paper 1 1.05 356,373 Frozen Statement Distribution 234,176 paper statements = 6,004,514 frozen DB Statem…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  7. PLR 202503002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJan 17, 2025
    …oner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  8. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
  9. PLR 202452004 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 27, 2024
    …oner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  10. 31 T.C. 1182 — Finnie Co. v. United States
    IRCCourt RulingsMar 24, 1959related by meaning
    for shipment. Moreover, petitioner’s managing partners brought with them the benefit of the corporation’s many years of experience in an allied field. Having taken these, and the other statutory factors into consideration, including, but not limited to the amount of private capital involved, the relationship of profits…
  11. PLR 201117012 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsApr 29, 2011
    …ner , 306 F.2d 682, 687 (1 st Cir. 1962), aff’g Archibis hop Samuel Trust v. Commissioner , 36 T.C. 641 (1961), acq ., 1964-2 C.B. 3 [i]nherent in the concept of an annuity is a transfer of cash or
  12. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  13. PLR 202444003 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsNov 1, 2024
    …ioner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Commissioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  14. PLR 200949007 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 4, 2009
    …oner , 306 F.2d 682, 687 (1 st Cir. 1962), aff’g Archibishop Samuel Trust v. Commissioner , 36 T.C. 641 (1961), acq ., 1964-2 C.B. 3 [i]nherent in the concept of an annuity is a transfer of cash or
  15. PLR 202250010 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 16, 2022
    …oner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  16. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  17. PLR 202250011 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 16, 2022
    …oner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  18. PLR 202250012 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsDec 16, 2022
    …oner , 306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36 T.C. 641 (1961), acq. , 1964-2 C.B. 3: Inherent in the concept of an annuity is a transfer of cash or property from one party to another in return for a promise to pay a specific periodic sum for a stipulated time interval . …
  19. 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).
  20. PLR 199925042 — Deduction for Contributions of Employer to an Employee's Trust or Annuity Plan and Compensation Under a Deferred-Payment Plan (Deduct. v. Not Deduct.)
    IRCPrivate Letter RulingsJun 25, 1999
    …ee United States v. General Shoe Corporation , 282 F.2d 9 (6 th Cir. 1960), cert. denied , 363 U.S. 641 (1961); and International Freighting Corp., Inc. v. Commissioner , 45 B.T.A. 716 (1941), aff’d , 135 F.2d 310 (1943). 7 16