Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 38 T.C. 643 (not yet in the library — opens the official source)
78 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  2. 61 T.C. 605; 61 T.C. No. 65 — Estate of Silverman v. Commissioner
    IRCCourt RulingsFeb 4, 1974
    …se would lie in Commissioner v. Estate of Albright, 356 F. 2d 319 (C.A. 2, 1966), reversing 42 T.C. 643 (1964). The portion of section 2039(c) involved in the Albright case was the provision that “no exclusion shall be allowed for that portion of the value of such amount [amounts payable after death of the decedent und…
  3. 73 T.C. 779 — Woodson v. Commissioner
    IRCCourt RulingsFeb 5, 1980
    …distribution which represents contribution to the trust following the loss of its exempt status ($2,643.39) is a distribution from a nonqualified plan and is ordinary income. Petitioners, citing the Second Circuit's decision in Greenwald v. Commissioner, 366 F.2d 538 (2d Cir. 1966), revg. in part 44 T.C. 137 (1965), ar…
  4. PBGC Op. Ltr. 1992-4 — Withdrawal liability
    PBGCPBGC Opinion LettersJun 18, 1992
    …C has issue d its regu lation o n Va riance s for Sa le of Ass ets (29 CFR Par t 264 3). Se ction 2 643 .11( a) of the regula tion pr ovid es that: A purch aser 's bond or es crow u nder s ecti on 4204(a) (1)( B) of [ ERISA] and t he sa le- contr act provi sion [*3] under sect ion 420 4(a) (1)(C ) are no t requir ed if…
  5. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  6. 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…
  7. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  8. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
  9. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012★ strong match
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  10. 84 FR 53579 — Real Estate Appraisals
    IRCFinal Rules (FR)Oct 8, 2019
    …l property that sold for $250,000 as of June 30, 1994, would be expected to sell in March 2019 for $643,750 according to the Case-Shiller Index and $621,448 according to the FHFA Index (see Table 1 below). The agencies also considered housing prices over the most recent financial cycle which were generally at a low poi…
  11. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  12. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    on. Background The following facts are derived from the parties’ pleadings, M otion papers, and the Exhibits attached to petitioner’s Motion. They are stated solely for the purpose of deciding the Motion and not as findings of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17 …
  13. Notice 2008-108 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the…
    IRCNoticesDec 15, 2008
    401(a)(31) was amended by § 643(b) of EGTRRA to allow employees’ after-tax contributions to be rolled over under certain circumstances. (2004 C. L.). Section 401(a)(31)(B) was amended by § 657(a) of EGTRRA (as amended by § 411(t) of JCWAA) to provide for the automatic rollover of certain mandatory distributions. The e…
  14. T.C. Memo. 2016-29 — Mark Vandenbosch & Julie Vandenbosch v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    …'g in part 11 T.C.M. (CCH) 274 (1952); Shaara v. Commissioner, T.C. Memo. 1980-247, 40 T.C.M. (CCH) 643 (1980). ¹8Lashells' Estate v. Commissioner, 208 F.2d at 433; Shaara v. Commissioner, 40 T.C.M. (CCH) at 644-645. - 18 -
  15. Notice 2007-3 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66, 2005-2 C.B. 509, pertaining to th…
    IRCNoticesModified Jan 8, 2007
    …L.). Notice 2001-56, 2001-2 C.B. 277. (2004 C. L.). 401(a)(31): Section 401(a)(31) was amended by § 643(b) of EGTRRA to allow employees’ after-tax contributions to be rolled over under certain circumstances. (2004 C. L.). Section 401(a)(31)(B) was amended by § 657(a) of EGTRRA (as amended by § 411(t) of JCWAA) to provi…
  16. Notice 2007-94 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-28 I.R.B. 54, pertaining to …
    IRCNoticesDec 17, 2007
    …L.). Notice 2001-56, 2001-2 C.B. 277. (2004 C. L.). 401(a)(31): Section 401(a)(31) was amended by § 643(b) of EGTRRA to allow employees’ after-tax contributions to be rolled over under certain circumstances. (2004 C. L.). Section 401(a)(31)(B) was amended by § 657(a) of EGTRRA (as amended by § 411(t) of JCWAA) to provi…
  17. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    Commissioner , 83 T.C. 755, 791 n.28 (1984); Kahler v. Commissioner , 18 T.C. 31, 34-35 (1952); Roberts v. Commissioner , T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not subject to substantial limitations, and petitioner makes no contention otherwise. Consequently, we find…
  18. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    …o this case, also amended section 415(c)(3)(D). - 25 - [*25] CRA sec. 314(e)(1), 114 Stat. at 2763A-643, amended section 415(c)(3)(D) to require that "compensation" include any amount an employer contributed or deferred at the election of the employee and which is not includible in the gross income of the employee by r…
  19. Notice 2004-84 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Announcement 2004-71, 2004-40 I.R.B. 569, pertaining …
    IRCNoticesModified Dec 27, 2004
    …limit to $200,000. Notice 2001-56, 2001-2 C.B. 277. 401(a)(31): Section 401(a)(31) was amended by § 643(b) of EGTRRA to allow employees’ after-tax contributions to be rolled over under certain circumstances. Section 401(a)(31)(B) was amended by § 657(a) of EGTRRA (as amended by § 411(t) of JCWAA) to provide for the aut…
  20. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    section 6651(a)(1)2 and (2) in the amounts of $4,120 .43, and $3,204 .78, respectively ; an d (4) whether petitioner is liable for an addition to tax under section 6654(a) in the amount of $486 .95 for failure to pay estimated income tax . 1 The actual amount of the deficiency remaining unpaid, $18,313 plus applicable…