84 FR 37508 — Definition of “Employer” Under Section 3(5) of ERISA-Association Retirement Plans and Other Multiple-Employer Plans ERISAFinal Rules (FR)Jul 31, 2019
…ement Plans,”
ICI Research Perspective,
vol. 23, no. 05, (July 2017).
Back to Citation
57.
Section 522 of the Bankruptcy Code (11 U.S.C. 522), provides an unlimited exemption for SEP and Simple IRAs, and pension, profit sharing, and qualified plans, such as 401(k)s, as well as plan assets that are rolled over to an IR…
49 T.C. 174 — Armanco Productions, Inc. v. Commissioner IRCCourt RulingsDec 8, 1967related by meaning
dic or annual compensation on the basis of permanent employment;
(c) Are full-time employees who have not attained the age of seventy-five (75) years; (d) All personnel employed by the Company as of the effective date of this Trust shall be eligible to become Participants therein. All personnel employed subsequent to F…
IRCPrivate Letter RulingsAug 27, 1999
…that were
fixed with regard to specific employees.
6
See Senate Report No. 93-1357, 1975-1 C.B.
521-522.
In Taxpayer-Group's case, the accruals were determined as to specific
employees. Each employee's anniversary date was the date of reference for
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
83 FR 53534 — Definition of “Employer” Under Section 3(5) of ERISA-Association Retirement Plans and Other Multiple-Employer Plans ERISAProposed Rules (FR)Proposed Oct 23, 2018
…ment Plans,”
ICI Research Perspective,
vol. 23, no. 05, (July 2017.).
Back to Citation
56. Section 522 of the Bankruptcy Code (11 U.S.C. 522), provides an unlimited exemption for SEP and Simple IRAs, and pension, profit sharing, and qualified plans, such as 401(k)s, as well as plan assets that are rolled over to an IR…
81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
tion
45.
15 U.S.C. 80b-11(g)(1).
Back to Citation
46.
See e.g., Fish
v.
GreatBanc Trust Company,
749 F.3d 671 (7th Cir. 2014).
Back to Citation
47. As a practical matter, one way for financial institutions to ensure that they can meet this burden is by implementing strong anti-conflict policies and procedures, and …
IRCCourt RulingsJun 17, 1997
… following data:
1988
1989
1990
1991
1992
Total income $1,130,895 $1,108,792 $923,488 $114,270 $603,522
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…the four corners of the
document. See Lafayette Land Acquisitions II, LLC v. Walls, 385 So. 3d
519, 522– 23 (Ala. 2023). Petitioner does not argue that the MIPSAs are
ambiguous or dispute any relevant portion of them. Because the issue
concerns petitioner’s dealings with third parties, and the MIPSAs are
not ambiguous,…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCPrivate Letter RulingsJan 9, 2015related by meaning
the
60-day period.
Therefore, the Service declines to waive the
60-day rollover requirement with respect to
the distribution
of Amount 1 from Plan B. No opinion is expressed as to the tax treatment of the transaction described herein
under the provisions of any other section
of either the Code or regulations which may …
IRCCourt RulingsFeb 10, 2009related by meaning
ic v . ,Commissioner , T .C . Memo . 1992--
609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . .
In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her
medical condition
. She explained at trial that although she
received treatment from doctors in 2005, she did …
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…ce
Financial Trust’s 2000 tax year , reporting ordinary income of $249.08
and interest income of $5,522.30. Special Agent Trogden reviewed the
return and accepted the income and expenses reported thereon.
For the remaining tax years at issue, Special Agent Trogden
IRCCourt RulingsMay 4, 2004related by meaning
ed to respondent under sec.
7491. In any event, we do not decide the issue in this case on
the burden of proof. Also, regardless of whether the $5,555 additional tax under sec. 72(t) would be considered an
“additional amount” under sec. 7491(c) and regardless of whether
the burden
of
production
with respect to this add…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
ary or other plan official having authority to terminate the authorization, a written notice of the intent of the plan to terminate authorization; and (2) Failure to return the form or some other written notification of the plan's intent to terminate the authorization within thirty (30) days from the date the terminati…
IRCCourt RulingsJun 28, 2010related by meaning
a reasonable .dispute
with respect to any item of income reported on an information
return filed with the Secretary by a third party
:and the taxpayer has "fully cooperated with the Secretary (including providing,,-,
within ,a reasonable period-of time, access to and inspection of,
all witnesses, information, and docum…
IRCCourt RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
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
…6 T.C. 600 (1956), aff’d
per curiam , 253 F.2d 267 (6
th
Cir. 1958) and Anderson v. Comm. , 67 T.C. 522
(1976), aff’d per curiam
, 583 F.2d 953 (7
th
Cir. 1978). Accordingly, contributions by
the A
trust to the A -F plans in satisfaction of TP 2, TP 5, TP 6, TP 9, TP 10 and TP 13's
liabilities under the plans would be …
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…