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85 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    … Entities   Prohibited transaction exemptions 2020-02 75-1 77-4 80-83 86-128 84-24 Retirement Plans 765,124 765,124 277,390 6,886 1,000 1,722 Individual Retirement Accounts 3,119,832 210 52,449 Pooled Employer Plans 382 Pooled Plan Providers 134 Broker-Dealers 1,894 1,894 Discretionary Fiduciaries 1,894 Registered Inve…
  2. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  3. 88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …uent years Burden hours Equivalent burden cost Burden hours Equivalent burden cost Legal 5,992 $954,765 5,992 $954,765 Clerical 101 6,435 101 6,435 Total 6,093 961,200 6,093 961,200 The Department assumes that this information will include seven pages with 94.2 percent of disclosures distributed electronically through …
  4. IRCCourt RulingsAug 3, 1979related by meaning
    istinguishing our opinion in that case, and we see none. On the basis of Orzechowski, we hold that the section 4973 tax applies in docket No. 9115-77. The notices of deficiency addressed to the petitioners in docket No. 9115-77 did not set forth separately the asserted deficiencies in individual income taxes and the as…
  5. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026
    …dard Termination, Post-Distribution Certification 1,485 1,460 $49,787.50 $2,007.50 Premiums 2,145 1,765 173,610.65 278.65 Reportable Events 521 0 0 0
  6. 87 FR 56912 — Initial Regulatory Flexibility Analysis for Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Sep 16, 2022
    …ice providers who provided services of “Investment Management” and “Named Fiduciary,” of which only 765 reported their business code. Out of these 765 providers, 339 reported their business code starting with the 2-digit NAICS code 52, yielding a ratio of 0.44 of potential QPAMs to other providers. Therefore, the Depar…
  7. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  8. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  9. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    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…
  10. 75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 1, 2010
    …547 2,547 2016 614 614 2,598 2,598 2017 627 627 2,652 2,652 2018 640 640 2,708 2,708 2019 654 654 2,765 2,765 2020 668 668 2,823 2,823 2021 or later 682 682 2,882 2,882 1  Table II-A. 2  Table II-B. 3  Table II-C. * * * * * Issued in Washington, DC, this 29th day of November 2010. Vincent K. Snowbarger, Deputy Director…
  11. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  12. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989
    …distributions from their individual retirement accounts (IRAs). Petitioner and his wife reported $9,765.80 in IRA distributions on their 1984 Federal income tax return. Petitioner and his wife also reported on Form 5329 the IRA distributions which were subject to an increased tax because they were prematurely distribut…
  13. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …ical adaptability to a use does not establish a market.” United Sta tes v. 27 Whitehurst , 337 F.2d 765, 771 – 772 (4th Cir. 1964) ; see also United States v. 494.10 Acres of Land , 592 F.2d 1130, 1132 (10th Cir. 1979) (stating that “if the ‘future’ is beyond or very much beyond the ‘near future,’ the use becomes specu…
  14. Treas. Reg. § 1.401(a)(9)-6(m)(4)(ii)(A) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    … 392,933 19,260 377,564 2031 864,291 385,115 381,339 19,462 365,653 2032 819,740 372,966 369,310 19,765 353,201 2033 775,430 360,265 356,733 19,955 340,310 2034 731,620 347,116 343,713 20,257 326,859 Table 5 to Paragraph (m)(4)(ii)(A) Year Survivorshipto startof year Interestdiscountto endof 2028 Mortalityrate duringye…
  15. T.C. Summary Opinion 2013-95 — Richard N. Brogan v. Commissioner
    IRCCourt RulingsNov 26, 2013
    …eeds the investment in the contract. Sec. 72(e)(1)(A), (5)(A), (C); Brown v. Commissioner, 693 F.3d 765, 768 (7th Cir. 2012), aff'g T.C. Memo. 2011-83; Sanders v. Commissioner, T.C. Memo. 2010-279; sec. 1.72-11(d), Income Tax
  16. T.C. Memo. 2022-29 — Shawn Stephen Salter v. Commissioner
    IRCCourt RulingsApr 5, 2022
    …axab le income of $69,067 and computed a tax of $13,195. It also determined an additional tax of $3,765, calculated as 10% of the early distribution from his retireme nt plan. S ee § 72(t). Thi s produced total tax of $16,960 , against which the IRS offset $10,851 of tax withheld by his payors, producing an outstanding…
  17. 31 T.C. 1022 — Judkins v. Commissioner
    IRCCourt RulingsFeb 25, 1959related by meaning
    y at the time it was terminated and hence section 165 (b) did not apply. Eespondent has cited no case which would require a different conclusion here. On the facts here involved it is our opinion that the distribution received by petitioner in the year 1955 was paid to him on account of his separation from the service …
  18. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    or an adequate and full consideration in money or money's worth. Generally, transfers pursuant to agreements in settlement of disputes between adverse parties are not subject to the gift tax. See Beveridge v. Commissioner, 1 0 T. C. 915 (1948); Estate of Noland v. Commissioner, T.C. Memo. 1984-209; Lampert v. Commissio…
  19. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …0 (treating a statute of limitations as a procedural rule); Anderson v. Unisys Corp. , 52 F.3d 764, 765 n.1 (8th Cir. 1995) 41 (“[W]e consider the limitations period a procedural rather than a substantive requirement, and have found that ‘ courts apply the procedure in effect when the case is before them. ’ ” (quoting …
  20. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    ining whether petitioner satisfies the return-filed safe harbor of section 6654(d)(1)(B)(i). Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of section 6654(d)(1)(B)(i) to make estimated tax payments equal to “90 percent of the tax” (i.e., his ulti…