78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013
… inspection, in the Public Disclosure Room of the Employee Benefits Security Administration, Room N-1513, U.S. Department of Labor, 200 Constitution Ave. NW., Washington, DC 20210.
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsMar 20, 1997
…, 277 F.2d 879, 882 (8th Cir.
1960), affg. 32 T.C. 815 (1959); Yelencsics v. Commissioner
, 74
T.C. 1513, 1529 (1980); Magnon v. Commissioner
, 73 T.C. 980, 997
(1980). Petitioners seek to distinguish the facts in many of the
above cases from those in the instant case on grounds that are
immaterial to the outcome. The …
IRCCourt RulingsMar 9, 2011related by meaning
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
IRCCourt RulingsDec 20, 2001
…e determinations,
respondent contends that under cases such as Yelencsics v.
Commissioner
, 74 T.C. 1513 (1980), Burien Nissan’s $2,000 monthly
payments to Mr. Stanford during the years at issue constitute
constructive dividends to Mr. Whitehead for those years. That is
because, according to respondent, by making those…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
77 FR 41716 — Amendment Relating to Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure/Web Page ERISAProposed Rules (FR)Proposed Jul 16, 2012
…ww.dol.gov/ebsa,
and will be made available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210.
ERISAProposed Rules (FR)Proposed Jun 3, 2014
…ww.dol.gov/ebsa,
and will be made available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT:
Kristen Zarenko, Office of Regulations and Interpretations, Employee Benefits Security …
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
ERISAProposed Rules (FR)Proposed May 7, 2014
… change to
www.regulations.gov and available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210, including any personal information provided.
FOR FURTHER INFORMATION CONTACT:
Amy Turner or Elizabeth Schumacher, Employ…
79 FR 13949 — Amendment Relating to Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAProposed Rules (FR)Proposed Mar 12, 2014
…http://www.dol.gov/ebsa, and made available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT:
Allison Wielobob, Office of Regulations and Interpretations, Employee Benefits Security…
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…
IRCProposed Rules (FR)Proposed Feb 24, 2014
… change to
www.regulations.gov
and available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210, including any personal information provided.
FOR FURTHER INFORMATION CONTACT:
Amy Turner or Elizabeth Schumacher, Employ…
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
.
76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes IRCFinal Rules (FR)Jun 24, 2011
…
and
http://www.dol.gov/ebsa,
and available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue, NW., Washington, DC 20210.
Department of Health and Human Services.
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…
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…
75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans ERISAProposed Rules (FR)Proposed Aug 30, 2010
…
http://www.regulations.gov
and
http://www.dol.gov/ebsa,
and at the Public Disclosure Room, Room N-1513, Employee Benefits Security Administration, U.S. Department of Labor, 200 Constitution Avenue, NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT:
IRCProposed Rules (FR)Proposed Dec 24, 2013
… change to
www.regulations.gov
and available for public inspection at the Public Disclosure Room, N-1513, Employee Benefits Security Administration, 200 Constitution Avenue NW., Washington, DC 20210, including any personal information provided.
FOR FURTHER INFORMATION CONTACT:
Amy Turner or Beth Baum, Employee Benefits…
IRCCourt RulingsMay 20, 1976related by meaning
ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment.
SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…