IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCPrivate Letter RulingsSep 14, 2007related by meaning
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IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsJul 13, 2010related by meaning
all of the contentions and arguments of
the parties that are not discussed herein, and we conclude that
they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits
:
"According to Section 6673, this court may penalize Petitioner up
to $25,000 for failure to complete the admin…
75 FR 42605 — Increase in Tax Rates on Tobacco Products and Cigarette Papers and Tubes; Floor Stocks Tax on Certain Tobacco Products, Cigarette Papers, and Cigarette Tubes; … IRCFinal Rules (FR)Jul 22, 2010related by meaning
riteria for denial, suspension, and revocation of permits, and the floor stocks tax. The temporary regulations took effect on the date of publication. In the temporary rule, TTB amended the tobacco and cigarette papers and tubes regulations in parts 40, 41, 44, and 46 to reflect the new excise tax rates, provided examp…
Rev. Rul. 2005-72 — 2006 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2006 are provided for use in … IRCRevenue RulingsNov 14, 2005related by meaning
Form W-4, Employee's Withholding Allowance Certificate. The rules are effective with respect to wages paid on or after January 1, 2006.
Notice 2005-85 2006 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OA…
IRCCourt RulingsSep 30, 1991related by meaning
tioners to believe that no taxable event was created by the above transactions for which any Federal excise tax returns would be required to be filed. On November 21, 1986, respondent issued a notice of deficiency to each petitioner, in the amounts set forth above, determining an excise tax pursuant to section 4975(a).…
IRCCourt RulingsJun 29, 2015related by meaning
e parties agree that there is no genuine dispute as to any material
fact. After reviewing the pleadings and the comprehensive stipulation of facts and the attached exhibits, we conclude that a decision may be rendered as a matter of
law.
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[*13] II. Statutory Framework
A. DISCs7
A DISC provides a mechanism for def…
Rev. Rul. 2003-85 — Excise tax; terminating defined benefit plan; reversion. This ruling describes the treatment of a transfer from a terminating defined benefit plan to a defined… IRCRevenue RulingsAug 11, 2003related by meaning
e $40X that the employer receives is subject to the 20 percent excise tax under § 4980(a) and is includible in income under § 61.
DRAFTING INFORMATION The principal drafters of this revenue ruling are Steven Linder of the Employee Plans, Tax Exempt and Government Entities Division and Vernon Carter of the Office of the…
80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
atio = 1.47 × (1,400,000/10,509,091) = 0.196 = 19.6 percent.
Proposed Revocation of Parts I(b), I(c) and II(2) of PTE 75-1 and Restatement of PTE 75-1 The Department is proposing to revoke Parts I(b), I(c) and II(2) of PTE 75-1. In connection with the proposed revocation of Part II(2), the Department is republishing Pa…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
ce with the procedures set forth in 29 CFR part 2570, subpart B (76 FR 66637, October 27, 2011).
I. A new section I.E. is inserted to read as follows: Exception.
No relief from the restrictions of 406(b) and the taxes imposed by section 4975(a) and (b) by reason of sections 4975(c)(1)(E) and (F) is available for fiduci…
IRCCourt RulingsDec 5, 2007related by meaning
rease in
basis resulting from the disallowance of deductions claimed by
the PC .
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income and have rejected all arguments not discussed herein as irrelevant or without merit . Accordingly ,
Decisions will be entere d
under Rule 155 .
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsMay 13, 2013related by meaning
Petitioner failed to satisfy the requirements of Neonatology Assocs. to
establish reasonable cause or that she acted in good faith with respect to any portion of the underpayment of tax or that any portion of the underpayment is due
to reasonable cause. Petitioner is liable for the section 6662(a) accuracy-related
pena…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
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5
See also …
IRCCourt RulingsSep 25, 2000related by meaning
lity for the excise
taxes and that petitioner was liable for the additions to tax
under section 6651(a)(1).
Discussion
I. Liability Under Section 4975 A. The Statutes
Section 4975 was added to the Internal Revenue Code by title
II of the Employee Retirement Income Security Act of 1974
(ERISA), Pub. L. 93-406, sec. 2003…
IRCPrivate Letter RulingsJun 14, 2019related by meaning
Internal Revenue Service
Department of the Treasury
Wa shington, DC 20224
Number: 201924013
Release Date: 6/14/2019
Index Number:
401.06-00, 401.06-02, 408.00-00, 408.08-00
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IRCPrivate Letter RulingsSep 21, 2007related by meaning
,