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87 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …00 257,880 21,630 279,51 0 3 279,510 25,000 254,510 21,361 275,87 1 4 275,871 25,000 250,871 21,070 271,94 1 5 271,941 25,000 246,941 20,755 267,69 6 6 267,696 25,000 242,696 20,416 263,11 2 7 263,112 25,000 238,112 20,049 258,16 1 8 258,161 25,000 233,161 19,653 252,81 4 9 252,814 25,000 227,814 19,225 247,03 9 10 247…
  2. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  3. T.C. Summary Opinion 2018-15 — Gary K. Sherman & Gwendolyn L. Sherman a.k.a. Gwen L. Sherman v. Commissioner
    IRCCourt RulingsApr 2, 2018
    …le 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). 4Peterson v. Commissioner, T.C. Memo. 2013-271, at *8, aff'd in part, dismissed in part, 827 F.3d 968 (11th Cir. 2016); see sec. 1402(a). 5Jackson v. Commissioner, 108 T.C. 130, 134 (1997). - 9 - self-employment tax provisions are broadly construed in favor of tr…
  4. 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…
  5. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …rest—Retirement Investment Advice Regulatory Impact Analysis for Final Rule and Exemptions, pp. 268-271, (April 2016), https://www.dol.gov/​sites/​dolgov/​files/​EBSA/​laws-and-regulations/​rules-and-regulations/​completed-rulemaking/​1210-AB32-2/​ria.pdf. Back to Citation 235.  Employee Benefits Security Administratio…
  6. REG-139236-07 — Proposed regulations under section 430 of the Code provide guidance on the valuation of plan assets and the determination of benefit liabilities for purposes o…
    IRCProposed Rules (FR)Proposed Mar 3, 2008
    …$128,000 $66,000 Benefits Paid $(49,000) $(25,000) Expenses Paid $(14,500) $(7,500) Total $261,000 $271,500 $228,000 Average value as of January 1, 2019 equals: $261,000 + $271,500 + $228,000 ÷ 3 = $253,500 (iii) Conclusion. Having determined an average value as of January 1, 2019 equal to $253,500, Plan F must confirm…
  7. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  8. Treas. Reg. § 1.415(b)-1(e)(4) — Limitations for defined benefit plans.
    IRCRegulationsSep 9, 2016
    …1)(A) dollar limit at age 70 is $240,500 (the lesser of $240,500 ($185,000* $195,000/$150,000) and $271,444 (the straight life annuity at age 70 that is actuarially equivalent to an annuity of $185,000 commencing at age 65, determined using 5 percent interest and the applicable mortality table, without a mortality decr…
  9. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  10. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    … 16,737 32,545 Private Entities: Self-insured (States with Requirements) 217,651 158,885 58,766 114,271 Self-insured (States without Requirements) 401,392 293,016 108,376 210,739 Fully insured (States without Requirements) 314,761 229,775 84,985 165,256 Total Private 933,803 681,677 252,127 490,266 All Plans 995,792 72…
  11. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    lure to report any portion of the distributions. Thus, we find petitioner liable for the negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock. In keeping with the above holdings, Decision will be entered under Rule 155 .
  12. 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…
  13. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    articipants, Harold Breslow and Robert Levine, received their full benefit and petitioner signed an irrevocable waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we find no documentary evidence that all rank and file employees were paid their full vested interest, especially …
  14. 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…
  15. PLR 201923016 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsJun 7, 2019
    … opinion 749 F.2d 37 (9th Cir. 1984) ; American Nurseryman Publishing Co. v. Commissioner , 75 T.C. 271, 275 (1980) , affd . without published opinion 673 F.2d 133 3 (7th Cir. 1981) . . . . Wh ile we will look to local law in order to determine the nature of
  16. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    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…
  17. PLR 201628004 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …d opinion 749 F.2d 37 (9th Cir. 1984) ; American Nurseryman Publishing Co. v. Commissioner, 75 T.C. 271, 275 (1980) , affd. without published opinion 673 F.2d 1333 (7th Cir. 1981) . . . . Wh ile we will look to local law in order to determine the nat ure of the interests provided under a trust document, we are not boun…
  18. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  19. PLR 201628006 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    … opinion 749 F.2d 37 (9th Cir. 1984) ; American Nur seryman Publishing Co. v. Commissioner, 75 T.C. 271, 275 (1980) , affd. without published opinion 673 F.2d 1333 (7th Cir. 1981) . . . . Wh ile we will look to local law in order to determine the nature of the interests provided under a trust document, we are not bound…
  20. PLR 201628005 — Required Distributions
    IRCPrivate Letter RulingsJul 8, 2016
    …d opinion 749 F.2d 37 (9th Cir. 1984) ; American Nurseryman Publishing Co. v. Commissioner, 75 T.C. 271, 275 (1980) , affd. without published opinion 673 F.2d 1333 (7th Cir. 1981) . . . . Wh ile we will look to local law in order to determine the nat ure of the interests provided under a trust document, we are not boun…