Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 83 T.C. 217 (not yet in the library — opens the official source)
68 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    es applicable t o annuity distributions from CRATs. Thus, to the extent sections 72 and 664 called for different treatment, section 664 would control. Second, section 7 2 do es not call for different treatment. Section 72(b)(1) allows an exclusion from income only to the extent the taxpayer has an “investment in the co…
  2. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
  3. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    ies thereby created. We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
  4. 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…
  5. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
  6. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    4). We do not find Rev. Rul. 69-647 intrinsically persuasive, and we agree with the Claims Court that it is distinguishable on its facts in any event. Of course, a distribution upon plan termination may be a ''qualifying rollover distribution” under sec. 402(a)(5)(D), and be rolled over into another qualifying plan. Se…
  7. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …it comments 216 .04 Right to comment if DOL declines to comment 216 .05 Confidentiality of comments 217 .06 Availability of comments 217 .07 When comments are deemed made 217 SECTION 19B. WHAT NOTICE REQUIREMENTS APPLY TO INTERESTED PERSONS (§ 403(b) PLANS ONLY)? 217 .01 Requirement to notify interested persons 217 .02…
  8. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
  9. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  10. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997
    …nce that petitioner did provide, such evidence either demonstrates that the requirements of section 217 were not met (in the case of certain pre-move househunting expenses claimed on the return) or is insufficient to show that the requirements of - 12 - section 217 have been satisfied (in the case of all remaining movi…
  11. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    me-generating activities relating to the items of income, he has satisfied that obligation through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation should have been divided between himself and his spouse, there is no basis for making any apportionment. …
  12. 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 …
  13. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  14. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989related by meaning
    nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
  15. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …t be given 216 .03 Content of notice 216 .04 Information to be made available to interested persons 217 .05 Information described in § 6110(c) should not be included 217 .06 Section 20B is not applicable to plan sponsors of governmental plans 217 PART IIC. PROCESSING DETERMINATION LETTER REQUESTS SECTION 21. HOW DOES E…
  16. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    … fewer than 26 participants 216 .07 Information described in § 6104(a)(1)(D) should not be included 217 .08 Availability of additional information to interested parties 217 .09 Availability of notice to interested parties 217 SECTION 20B. WHAT ARE THE GENERAL RULES FOR NOTICE TO INTERESTED PERSONS (§ 403(b) PLANS ONLY)…
  17. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
  18. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …)(1)(D) should not be included 216 .08 Availability of additional information to interested parties 217 .09 Availability of notice to interested parties 217 PART IIC. PROCESSING DETERMINATION LETTER REQUESTS SECTION 21. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HANDLE DETERMINATION LETTER REQUESTS? 217 .01 Oral ad…
  19. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…
  20. 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
    …6 SECTION 34. PAPERWORK REDUCTION ACT 216 DRAFTING INFORMATION 216 APPENDIX A-SCHEDULE OF USER FEES 217 .01 Letter ruling requests 217 .02 Opinion letters on prototype individual retirement accounts and/or annuities, SEPs, SIMPLE IRAs, SIMPLE IRA Plans, Roth IRAs and dual-purpose IRAs 217 .03 Opinion letters on master …