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85 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    … recommendations.”) Back to Citation 221.  The commenter cited the Chamber opinion, 885 F.3d at 372-373, as support for the assertion that financial professionals receive “no compensation” for the provision of advice that is incidental to brokerage services. On page 373, the Chamber
  2. 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 $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  3. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    …n (hours) Total estimated labor cost ($) 2022 326 326 48 15,638 $1,603,770.05 2023 326 326 12 3,910 373,158.29 2024 326 326 12 3,910 373,158.29 Three-year average 326 326 24 7,819 783,362 E. ICRs Regarding Air Ambulance Reporting Requirements for Providers of Air Ambulance Services (45 CFR 149.460)
  4. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …our burden is estimated to be 39,180 hours with an equivalent total annual cost of approximately $1,373,651. Table 8A—Estimated Annual Cost and Hour Burden per Health Insurance Issuer or TPA To Train Customer Service Representatives To Provide Assistance to Consumers Related to the Internet-Based Self-Service Tool Occu…
  5. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  6. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …r external review is estimated to be 4,0655 hours (16,261 * 0.25 hours) with an equivalent cost of $373,303 (4,065 hours * $91.83). The Departments assume that plans have a human resources specialist with a labor rate of $91.83. The human resource specialist will spend an average of 15 minutes for each of the requests,…
  7. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  8. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …1961) ( determining that the quid was education services provided by the donee), aff ’ d , 309 F.2d 373 (9th Cir. 1962). Nor did the Board of Supervisors compel the donation to a donee of its choice. Cf. Triumph Mixed Use Invs. III, LLC , T.C. Memo. 2018-65, at *35– 40 (determining that there was a quid pro quo exchang…
  9. 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…
  10. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
  11. Treas. Reg. § 1.401(l)-4(e)(3)(iii)(B) — Special rules for railroad plans.
    IRCRegulationsMay 18, 2016
    … allowance and maximum offset allowance (percent) 64 0.523 63 0.485 62 0.448 61 0.418 60 0.388 59 0.373 58 0.358 57 0.343 56 0.329 55 0.314 (e)(4) (4) Overall permitted disparity. The overall permitted disparity rules of § 1.401(l)-5 apply to employees who benefit under a plan maintained by a railroad employer.
  12. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    acted section 7476 to establish a declaratory judgment procedure under which an - 6 - employer could challenge respondent's determination with respect to the qualification of its employee benefit plan. H. Rept. 93-807, supra at 107, 1974-3 C.B. at 342. Section 7476 provides: SEC. 7476. DECLARATORY JUDGMENTS RELATING TO…
  13. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
  14. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    … USA, LLC, 118 F.4th 888, 895 (7th Cir. 2024) (citing Bell v. PNC Bank, Nat’l Ass’n , 800 F.3d 360, 373 (7th Cir. 2015)). First, they must show that the purported class meets Rule 23(a)’s requirements of numerosity, commonality, typicality, and adequacy of representation. See Fed. R. Civ. P. 23(a)(1) – (4). In addition…
  15. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980related by meaning
    . Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
  16. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  17. 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…
  18. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …5584(a), 8346(b), 8470(b) (2012); 10 U.S.C. secs. 1442, 1453(b)(2) (2012); 37 U.S.C. secs. 303a(e), 373(b) (2012); 38 U.S.C. sec. 5302(a) and (b) (2012); Intelligence Authorization Act for Fiscal Year 1993, Pub. L. No. 102-496, sec. 265, 106 Stat. at 3237-3238 (codified at 50 U.S.C. sec. 2095 (2012)); Social Security A…
  19. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
  20. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    drawn therefrom), but that, if such order were not a QDRO, petitioner’s ex-husband and not petitioner would be taxable in respect of the distribution. As will subsequently become apparent, such all-or-nothing treatment will not necessarily flow from our decision herein. Indeed, the road to decision herein is a rocky on…