IRCCourt RulingsSep 14, 1993related by meaning
B) simply does not apply here because we do not have a lump sum distribution within subparagraph (A).
2. 10-Percent Additional Tax Under Section 72(t) Petitioner has disputed the Commissioner’s imposition of a 10-percent addition to tax on the lump sum distribution. In the assignments of error in the petition to this C…
IRCCourt RulingsAug 30, 1993related by meaning
least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans ERISAProposed Rules (FR)Proposed Aug 30, 2010related by meaning
he same investment manager, and the execution of certain foreign exchange transactions between a plan and a bank or broker-dealer.
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3. Additional information concerning the requirements for obtaining administrative relief under PTE 96-62 (as amended) may be obtained by accessing the complete text of th…
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
ion under PTE 77-4. The Department requests comment on this proposed revocation, and also on how the remaining parts of PTE 75-1 Part II will be used. The Department is further proposing to revise the recordkeeping provisions of Section (e) of PTE 75-1, Part II. Section (e) currently provides that records demonstrating…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
87 FR 70753 — Prohibited Transaction Exemption (PTE) 2002-51 To Permit Certain Transactions Identified in the Voluntary Fiduciary Correction Program ERISAProposed Rules (FR)Proposed Nov 21, 2022related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03.
Taxpayer may protest deletions not made
.05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
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 RulingsFeb 22, 2010related by meaning
Print 1982) .
Sec . 7702 was enacted in 1984 as part of the Deficit Reduction
.
Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments
. postdate the promulgation of the
applicable regulations in 1956, for the reasons . discussed supra
we believe that the cross-reference to se…
IRCCourt RulingsJun 1, 1987related by meaning
ts by fiduciaries or other disqualified persons. No such substantial safeguards as indicated in the Conference report are present in the instant case. We determine that the subject lease transactions do not concern qualifying employer real property because such properties are not dispersed geographically. Sec. 407(d)(4…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
w why the statute as
enacted contains language different from that in the House and
- 10 -
1
We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize
this Court to grant a declaratory judgment include secs. 6234,
7428, 7477, 7478, and 7479.
2
Sec. 7503 a…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
85 FR 40589 — Conflict of Interest Rule-Retirement Investment Advice: Notice of Court Vacatur ERISAFinal Rules (FR)Jul 7, 2020related by meaning
individual.
Jeanne Klinefelter Wilson,
Acting Assistant Secretary, Employee Benefits Security Administration, U.S. Department of Labor.
Footnotes
1.
See 40 FR 50842-44 (Oct. 31, 1975).
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2.
The
Federal Register
citations for the applicable versions of the previously granted PTEs are as follows: PTE 75…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…