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82 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    INCOME TAX Rev. Rul. 2005-13 Rev. Rul. 2005-13 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2005. T.D. 9175 T.D. 9175 Temporary and proposed regula…
  3. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ON 18. WHAT ARE THE PROCEDURES FOR REQUESTING SECTION 401(h) and SECTION 420 DETERMINATION LETTERS? 184 .01 Scope 184 .02 Required information for § 401(h) determination 184 .03 Required information for § 420 determination 184 PART IIB. INTERESTED PARTY NOTICE AND COMMENT SECTION 19. WHAT RIGHTS TO NOTICE AND COMMENT D…
  4. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  5. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ll Suspense Account activity through October 31, 1994: - 35 - Total Out Total In Accounting fees $4,184 --- Actuarial gains --- $252,977 Administrative fees 192,000 --- Death benefit 3,398 --- Death forfeitures --- 474,839 Expense allocations 22,939 --- Interest earned --- 48,581 Legal fees 387,990 256 Miscellaneous 2,…
  6. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
  7. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    … III. DEFINITIONS, CORRECTION PRINCIPLES, AND RULES OF GENERAL APPLICABILITY SECTION 5. DEFINITIONS 184 .01 Definitions for Qualified Plans 184
  8. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
  9. 72 T.C. 117 — Dallas Dental Lab, Inc. v. Commissioner
    IRCCourt RulingsApr 12, 1979related by meaning
    e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
  10. Notice 2016-62 — Section 415 of the Internal Revenue Code (the Code) provides for dollar limitations on benefits and contributions under qualified retirement plans. Section 415…
    IRCNoticesNov 14, 2016
    …payer who is not an active participant but whose spouse is an active participant is increased from $184,000 to $186,000. Accordingly, under § 219(g)(2)(A), the deduction for taxpayers making contributions to a traditional IRA is phased out for single individuals and heads of household who are active participants in a q…
  11. 39 T.C. 362 — Wilson v. Commissioner
    IRCCourt RulingsNov 6, 1962related by meaning
    ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated. Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act. Thls section was originally desi…
  12. Notice 2015-75 — Section 415 of the Internal Revenue Code (the Code) provides for dollar limitations on benefits and contributions under qualified retirement plans. Section 415…
    IRCNoticesNov 16, 2015
    … not an active participant but whose spouse is an active participant is increased from $183,000 to $184,000. Accordingly, under § 219(g)(2)(A), the deduction for taxpayers making contributions to a traditional IRA is phased out for single individuals and heads of household who are active participants in a qualified pla…
  13. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …rectly by comparing its stock’s historical price movement to the market. Cf. Amazon I , 148 T.C. at 184 – 86, 198 (computing Amazon’s beta in 2005 by looking to monthly 87 The CAPM equation is stated as follows : 𝑟𝑟 𝑒𝑒 = 𝑟𝑟 𝑓𝑓 + 𝛽𝛽 ( 𝑟𝑟 𝑚𝑚 − 𝑟𝑟 𝑓𝑓 ) . 88 The risk-free rate of return was estimated by reference to the yi…
  14. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …ost James Josephine Cash/Checking $48,375 $24,188 $24,188 Money Fund 188,657 188,657 - Repo Account 184,155 184,155 - Mortgage 76,225 38,113 38,113 Mortgage 40,000 40,000 - Contract 34,433 34,433 - Note-1 26,815 26,815 - Note-2 2,300 2,300 - Note-3 80,000 80,000 - Note-4 17,500 17,500 - IRA-Kemper 9,000 9,000 - IRA-Kem…
  15. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    al right to decrease or altogether avoid such taxes by means which the law permits. Gregory v. Helvering, supra; Daniel D. Palmer, 62 T.C. 684 (1974). Respondent asserts that the result and reasoning of Rev. Rul. 68-303, 1968-1 C.B. 165, should control this case. In Rev. Rul. 68-303, a partnership entered into a contra…
  16. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …nticipated contribution $33,788,071 $39,519,000 $37,000,000 Investment income 1,084,333 1,264,000 1,184,000 Total projected income 34,872,404 40,783,000 38,184,000 Anticipated expenses 29,303,726 32,800,000 36,736,000 Projected surplus 5,568,678 7,983,000 1,448,000 1987 VEBA Contributions On December 22, 1987, the pens…
  17. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    ented are contained in pleadings and other documents in the record, and are not controverted. We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's 1991 taxable year. If respondent was not entitled to do so, then the August notice would not be valid as…
  18. 78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
    IRCFinal Rules (FR)Jun 3, 2013
    …port in a worksite smoking intervention. A test of theoretical models. Behav Modif, 2000. 24(2): p. 184-201; Okechukwu, C.A., et al., MassBuilt: effectiveness of an apprenticeship site-based smoking cessation intervention for unionized building trades workers. Cancer Causes Control, 2009. 20(6): p. 887-94; Sorensen, G.…
  19. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …nt investors receiving paper disclosures is estimated as: (3,183,503 retirement investors × 5.8%) = 184,643 paper disclosures. Back to Citation 479.  The cost is estimated as: (184,643 paper disclosures × 2 pages) × $0.05 = $18,464. Back to Citation 480.
  20. 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…