IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsFeb 25, 1959related by meaning
ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
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 RulingsFeb 20, 2003
…a deficiency in petitioner’s Federal
- 2 -
2
The notice of deficiency determined a deficiency of
$2,655 of which $124 represented tax on unreported interest
income, which petitioner concedes. Therefore, the amount of
deficiency at issue is $2,531.
income tax for the taxable year 1999 in the amount of $2,655.
After a co…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
IRCCourt RulingsNov 4, 1976related by meaning
loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
under section 4975 of the Code] is hereby transferred to the Secretary of Labor”).
Back to Citation
9.
29 CFR 2550.408b-2(e); 26 CFR 54.4975-6(a)(5). Back to Citation
10.
See
PTE 86-128, Exemption for Securities Transactions Involving Employee Benefit Plans and Broker-Dealers, 51 FR 41686 (November 18, 1986), as ame…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
78 FR 72018 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 2, 2013
…ter than—
From—
To—
2015
614
614
2,594
2,594
2016
627
627
2,651
2,651
2017
641
641
2,710
2,710
2018
655
655
2,769
2,769
2019
670
670
2,830
2,830
2020
685
685
2,893
2,893
2021
700
700
2,956
2,956
2022
715
715
3,021
3,021
2023
731
731
3,088
3,088
2024 or later
747
747
3,156
3,156
1
Table II-A.
2
Table II-B.
3
Table II-C.…
ERISACourt RulingsAug 10, 2026
…not encompass the stock appraisal reports
and trustee meeting minutes at issue in that case. Id. at 655. But it did encompass funding
and investment policies because they “set forth [] obligations to fund the [ plan ] and
IRCCourt RulingsNov 12, 1981related by meaning
n was for personal purposes; the petitioners have utterly failed to produce such evidence, and therefore, we sustain the Commissioner’s determination. The final issue for decision is whether any part of the underpayment of tax for 1975 was due to negligence or intentional disregard of rules and regulations within the m…
ERISACourt RulingsAug 10, 2026
…not encompass the stock appraisal reports
and trustee meeting minutes at issue in that case. Id. at 655. But it did encompass funding
and investment policies because they “set forth [] obligations to fund the [ plan ] and
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
83 FR 63802 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 12, 2018
…um 3
if monthly benefit at URA is—
High 4
if
monthly
benefit at
URA is
greater than—
From—
To—
2020
655
655
2,767
2,767
2021
670
670
2,831
2,831
2022
686
686
2,896
2,896
2023
701
701
2,963
2,963
2024
718
718
3,031
3,031
2025
734
734
3,100
3,100
2026
751
751
3,172
3,172
2027
768
768
3,245
3,245
2028
786
786
3,319
3,319
…
IRCCourt RulingsAug 31, 1978related by meaning
41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
80 FR 74986 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 1, 2015
…ly benefit at URA is greater than—
From—
To—
2017
627
627
2,647
2,647
2018
640
640
2,705
2,705
2019
655
655
2,767
2,767
2020
670
670
2,831
2,831
2021
686
686
2,896
2,896
2022
701
701
2,962
2,962
2023
718
718
3,030
3,030
2024
734
734
3,100
3,100
2025
751
751
3,171
3,171
2026 or later
768
768
3,244
3,244
1
Table II-A.
2…
IRCCourt RulingsSep 30, 2003related by meaning
ance with its substance.”
Neonatology Associates, P.A. v. Commissioner
, 299 F.3d 221, 230
n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is
free to organize his affairs as he chooses, nevertheless, once
having done so, he must accept the tax co…
IRCCourt RulingsJan 31, 2001
…-half (1/2) of
returned bail money.
- 15 -
(e) $1,000.00 – from the MacDill Credit Union;
and,
(f) $655.00 – cash from Husband.
It is unclear what the State Court meant by “the parties’
IRCCourt RulingsMay 23, 1979related by meaning
oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
IRCCourt RulingsOct 11, 1995related by meaning
tion that petitioners
are liable for the 10-percent additional tax imposed by section
72(t).
Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph
(1), which imposes the tax, provides in relevant part as follows:
(1) Imposition of Additional Tax.--If an…