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87 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  2. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    …the net operating loss of Angelo J. Bianchi, P.C. for the taxable year ended November 30, 1970, is $278.59 and that you are entitled to a net operating loss deduction of $278.59 rather than $16,946.11 as claimed on your return. Computation of allowable deduction of Angelo J. Bianchi, P.C. for contribution to its pensio…
  3. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    o be treated as an amount received as a loan on the date of such renegotiation, extension, renewal, or revision. TEFRA, sec. 236(c), 96 Stat. 510-511. In general, a loan fits within the exception in section 72(p)(2) if it (1) is in an amount not exceeding a prescribed ceiling that in no event may be more than $50,000, …
  4. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026
    …n, Post-Distribution Certification 1,485 1,460 $49,787.50 $2,007.50 Premiums 2,145 1,765 173,610.65 278.65 Reportable Events 521 0 0 0
  5. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …tates v. Kintner, 216 F.2d 418 (9th Cir. 1954). See the cases cited in Rev. Rui. 70-101,1970-1 C.B. 278. See T.I.R. 1019 (Aug. 8, 1969). See also Rev. Rui. 70-101, 1970-1 C.B. 278, where the Service also stated that it would recognize as a professional service corporation a corporation organized and operated as such un…
  6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
  7. 89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption
    PBGCFinal Rules (FR)Dec 20, 2024
    …2 946 946 3,996 3,996 2033 968 968 4,088 4,088 2034 990 990 4,182 4,182 2035 or later 1,013 1,013 4,278 4,278 1  Applicable tables for valuation dates before 2025 are available on PBGC's website ( www.pbgc.gov). 2  Table II-A. 3  Table II-B. 4  Table II-C. * * * * * Issued in Washington, DC. Hilary Duke, Assistant Gene…
  8. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  9. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    … × 99% proportion of entities are small Independent Producers × 5% create disclosure) × 1 hour] ≉ 4,278 hours. Applying a labor rate for an Independent Producer results in: (4,278 hours × $165.29) ≉ $707,142. For insurers: 358 insurers × 73.1% proportion of entities that are small × 1 hour ≉ 261 hours. Applying a labor…
  10. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  11. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …  (A) (B) (C) (D) (E) (F) (G) (H) Provider: PP 1,988 8,020 139,973,458 6,998,673 2,332,891 $818,582,278 $257,516,169 $1,076,098,447 Total 1,988 139,973,458 6,998,673 2,332,891 818,582,278 257,516,169 1,076,098,447 Table 4—Cost Savings from Rule Total costs of policy alternative without permitted practices Cost savings …
  12. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ted average) yield an estimate of a reduction in the net retail price of approximately one percent.[278] The preceding transfers-focused section discussed overall drug price reductions ranging from 0.1 percent up to this one percent, and the same range will be used in the benefits analyses appearing below, with most of…
  13. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968related by meaning
    -10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
  14. 148 T.C. No. 22 — Steven M. Petersen & Pauline Petersen v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …statement (Third) of Trusts for common law definition of a "trust"); United States v. De Bonchamps, 278 F.2d 127, 133 (9th Cir. 1960) (holding that a relationship is generally classified as a
  15. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012★ strong match
    …115,707 $1,142,511 Itemized deductions 122,512 110,429 27,462 Taxable income (loss) 1,296,048 1,005,278 1,115,049 Income tax 478,797 358,773 350,805 Brownsville Medical reported the following relevant amounts on its Federal income tax returns: 2001 2002 2003 Total incomel $2,527,967 $2,316,241 $2,137,828 Less: Total de…
  16. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  17. T.C. Summary Opinion 2008-32 — David K. Carlson v. Commissioner
    IRCCourt RulingsMar 31, 2008
    …ement . See Smith v . Commissioner , 370 F .2d 178, 180 (6th Cir . 1966), affg . T .C . Memo . 1964-278 ; Haag v . Commissioner , su ra at 616 n .6 . The aforementioned factors are not exclusive, and no one factor is dispositive . See John Kelley Co . v . Commissioner , 326 U .S . 521, 530 (1946) ; Smith v . Commission…
  18. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  19. Treas. Reg. § 1.417(e)-1(d)(6)(ii)(B) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    … and the present value factor for a temporary annuity payable to that participant until age 65 is 4.278. The benefit payable to Participant R in the form of a Social Security level income option (with a decrease of $1,000 occurring at age 65) that is actuarially equivalent to the early retirement benefit of $1,300 is $…
  20. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985related by meaning
    the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …