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 RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
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 …
IRCCourt RulingsJun 1, 1987related by meaning
transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein,
Decision will be entered for the respondent.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
IRCCourt RulingsNov 21, 2007
…August 31, 1998 . That statement records a "stock rollover
DS" on August 24, 1998, consisting of 10,323 shares of J .D .
Edwards & Co . stock valued at $40 .50 per share in the aggregate
amount $418,081 .50 . It is not clear from the record why the
rollover was not booked into petitioner's account as of August 4,
1998,…
89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
nd in its text, PTE 2020-02 has been broadly amended to encompass compensation for advice irrespective of the product recommended.
Back to Citation
6. ERISA section 408(a) and Code section 4975(c)(2), expressly permit the Department (through the Reorganization Plan No. 4 of 1978) to grant “a conditional or uncondition…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * 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 w…
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…
IRCCourt RulingsDec 8, 1987related by meaning
r the petitioner in docket No. 42535-84; decisions will be entered under Rule 155 in docket Nos. 42536-84, 42537-84, 42538-84, 42539-84, and 42540-84. AU statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue, unless otherwise indicated.
The Tax Equity and Fiscal Responsibi…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
…24, that apply to plans described in Code section 4975).
Back to Citation
11.
See
PTE 77-9, 42 FR 32395 (June 24, 1977) (predecessor to PTE 84-24).
Back to Citation
12.
15 U.S.C. 80a-2(a)(29).
Back to Citation
13.
Advisory Opinion 80-30A (May 21, 1980).
Back to Citation
14.
85 FR 49595 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Aug 14, 2020
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, rate set 323 is added at the end of the table to read as follows:
( printed page 49596)
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a
valuation date
Immediate
annuity rate
(…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsNov 21, 2023
…ployer-employee
relationship exists. See, e.g. , Nationwide Mut. Ins. Co. v. Darden , 503
U.S. 318, 323 – 24 (1992); Cmty . for Creative Non - Violence v. Reid , 490
U.S. 730, 751 – 52 (1989); Matthews v. Commissioner, 92 T.C. 351, 360
(1989), aff ’ d , 907 F.2d 1173 (D.C. Cir. 1990). Moreover, where a family
relations…
IRCCourt RulingsJun 18, 1997related by meaning
r personal injuries or
sickness to the extent such amounts are (A) attributable to
- 11 -
7
Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining
age 65 by completely disabled persons retired on disability.
Sec. 105(d) was repealed by sec. 122(b) of t…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMay 23, 2011
ication of common law
concepts. See Nationwide Mut. Ins. Co. v. Darden, 503 U.S. 318,
322-323 (1992); Weber v. Coèmissioner, 103 T.C. 378, 386 (1994), affd. per curiam 60 F.3d 1104 (4th'Cir'. 1995); Profl. & Exec.
Leasing, Inc. v. Commissioner, 89 T.C. 225, 232 (1987), affd. 862
F.2d 751 (9th Cir. 1988). Among the rele…
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…