PBGCCode / StatuteJan 6, 2017
…plan is amended to adopt another method authorized under subsection (b) or (c).
(d)(2) (2) Sections 1384, 1389, 1399(c)(1)(B), and 1405 of this title shall not apply with respect to the withdrawal of an employer from a plan described in paragraph (1) unless the plan is amended to provide that any of such sections apply…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
78 FR 20039 — Reportable Events and Certain Other Notification Requirements PBGCProposed Rules (FR)Proposed Apr 3, 2013
…The authority citation for part 4204 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1384(c).
§ 4204.12
[Amended]
8. Section 4204.12 is amended by removing the figures “412(b)(3)(A)” and adding in their place the figures “431(b)(3)(A)”.
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025
…The authority citation for part 4204 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1384(c).
§ 4204.11
[Amended]
31. Amend § 4204.11 by removing “(Approved by the Office of Management and Budget under control number 1212-0021)”.
§ 4204.21
[Amended]
32. Amend § 4204.21 by removing “(Approved by the Offic…
IRCCourt RulingsJan 26, 1984related by meaning
act represents reallocated forfeitures, the parties may be able to handle the matter under Rule 155, if that can be done without reopening the record. The Nov. 9,1977, letter stated the reasons for the proposed adverse determination as follows:
The final adverse determination letter, dated Mar. 28, 1979, stated in pert…
86 FR 1256 — Methods for Computing Withdrawal Liability, Multiemployer Pension Reform Act of 2014 PBGCFinal Rules (FR)Jan 8, 2021
…The authority citation for part 4204 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1384(c).
4. In § 4204.2, add in alphabetical order a definition for “Unfunded vested benefits” to read as follows:
§ 4204.2
Definitions.
* * * * *
Unfunded vested benefits
means, as described in section 4213(c) of ERISA,…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
84 FR 2075 — Methods for Computing Withdrawal Liability, Multiemployer Pension Reform Act of 2014 PBGCProposed Rules (FR)Proposed Feb 6, 2019
…The authority citation for part 4204 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1384(c).
4. In § 4204.2, add in alphabetical order a definition for “Unfunded vested benefits” to read as follows:
§ 4204.2
Definitions.
* * * * *
Unfunded vested benefits
means, as described in section 4213(c) of ERISA,…
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…
IRCCourt RulingsMar 25, 1996related by meaning
T.C. Memo. 1996-146
UNITED STATES TAX COURT
LLOYD PATTERSON, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1254-94. Filed March 25, 1996.
Lloyd Patterson, pro se.
Patricia Riegger
, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge
: This case was heard pursuant to
section 7443A(b)(…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsDec 19, 1974
…. United States v. Johnson, 331 F.2d 943, 952 (C.A. 5, 1964); Wysong v. United States, 326 F. Supp. 1384, 1387 (D. Minn. 1971); Maurice Osterman, 50 T.C. 970, 972, 974 (1968); Jack E. Schlegel, 46 T.C. 706, 710 (1966); Lester B. Martin, 26 T.C. 100, 106 (1956); Mary Miller, 22 T.C. 293, 301 (1954), affirmed per curiam …
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
Rev. Proc. 2010-48 — This procedure provides guidance to drafters and users of pre-approved IRAs. Section 3 provides guidance to drafters and users of prototype IRAs, including rul… IRCRevenue ProceduresDec 13, 2010
…and Tax Relief Reconciliation Act of 2001 (“EGTRRA”), Pub. L. 107-16. .03 Ann. 2007-55, 2007-1 C.B. 1384, provided guidance to sponsors of prototype Roth IRAs who wished to amend their documents to accept rollovers from designated Roth accounts described in § 402A.
.04 Notice 2009-82, 2009-41 I.R.B. 491, provides that …
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsSep 23, 2014related by meaning
pretation of the statute was "unduly narrow" and ran counter to the plain
meaning of the statute), rev'g 102 T.C. 61 (1994); Matthews v. Commissioner, 907 F.2d 1173, 1179 (D.C. Cir. 1990) (holding that the language of the statute is
"too plain to be mistaken"), aff'g 92 T.C. 351 (1989).
And the Supreme Court has remind…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsNov 25, 2008related by meaning
, after holding that the
taxpayer had no unpaid income tax for that year) ; Rowe v .
Commissioner , T .C . Memo . 2001-325 (holding that the Court has jurisdiction to review the Commissioner's denial of section
6015(f) relief from additions to tax and penalties) .
We hold that "taxes" in TRHCA section 408(c) includes t…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.