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86 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …ERISA-covered group health plans with less than 100 employees, of which 1,400,000 are fully funded.[239] For purposes of the RFA, the Department of Labor continues to consider a small entity to be an employee benefit plan ( printed page 60504) with fewer than 100 participants.[240]
  2. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    … Lung Benefits Act Failure to report termination of payments 20 CFR 725.621(b), (d) 1978 Pub. L. 95-239 500 550 1,375. OWCP Black Lung Benefits Act Failure to file required reports 20 CFR 725.621(d) 1978 Pub. L. 95-239 500 550 1,375. OWCP Black Lung Benefits Act Failure to secure payment of benefits 20 CFR 726.300 1978…
  3. 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…
  4. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  5. 60 T.C. 469; 60 T.C. No. 52 — Estate of Bell v. Commissioner
    IRCCourt RulingsJun 26, 1973
    …investment in the contract” is the fair market value of the stock transferred, relying on Rev. Rul. 239, 1953-2 C.B. 53, which applied to a similar computation under section 22(b) (2) of the Revenue Act of 1939. Petitioners further contend that the fair market value of the stock was not less than $207,600. In our opini…
  6. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012
    … Sec. 6662 McKays $1,249,848 $214,786 Pedersens 1,204,920 240,984 Nellesens 813,307 162,661 Jensens 239,543 47,909 Neffs 232,438 46,487 Loves 38,582 7,716 The primary issue for decision is whether petitioners' principal purpose in acquiring stock in their respective S corporations was the evasion or avoidance of Federa…
  7. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    Tannenwald, Judge: Respondent determined deficiencies in the Federal income tax of petitioner for 1971, 1972, and 1973 in the respective amounts of $3,576.58, $4,052.04, and $3,912 together with negligence penalties under section 6653(a). The negligence penalties have been conceded by respondent, and capital loss adjus…
  8. 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…
  9. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …Employee contributions during year N/A 473,833 736,176 784,906 K. Interest to yearend 4 498,812 896,239 1,225,134 1,454,591 L. Account limit (yearend) 5 8,056,566 14,031,392 20,657,080 28,881,609 M. Actual contribution 30,689,717 2,170,000 13,966,816 12,247,933 N. Value of assets (yearend) 30,736,554 30,176,217 39,940,…
  10. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  11. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  12. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …f the enactment of this Act . . . .”) ; Omnibus Budget Reconciliation Act of 1989, Pub. L. No. 101- 239, § 7731(d) , 1 03 Stat. 2106, 2402 (“The amendments made by this section shall apply to positions taken . . . in proceedings which are pending on [ December 31, 1989. ]” ). Because 9 Congress did not employ wording r…
  13. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    Atkins, Judge: The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…
  14. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    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…
  15. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    ent with the intent of DEFRA, and because it permissibly fills a gap created by sections 419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is not impermissibly broader than sections 419 and 419A and, accordingly, we hold that it is valid. Chevron…
  16. 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…
  17. PLR 201639001 — Medical, Etc. Benefits
    IRCPrivate Letter RulingsSep 23, 2016
    …ansition rule set forth in Section 7311 of the Omnibus Budget Reconciliati on Act of 1989 (P.L. 101-239), all of the eligibility conditions for which Company A satisfied, Company A made direct contributions to the Retirement Plan A 401(h) account of approximately $Y. At no time did Company A transfer any assets from Re…
  18. 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…
  19. PLR 201611003 — Medical, Etc. Benefits
    IRCPrivate Letter RulingsMar 11, 2016
    …ransition rule set forth in Section 7311 of the Omnibus Budget Reconciliation Act of 1989 (P.L. 101-239), all of the eligibility conditions for which Parent Company satisfied, Parent Company made direct contributions to the Retirement Plan A 401(h) account of approximately Amount 1. At no time did Parent Company transf…
  20. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein, Decision will be entered for the respondent. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…