Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 98 T.C. 368 (not yet in the library — opens the official source)
82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2007-333 — Jeanne E. Amarasinghe v. Commissioner
    IRCCourt RulingsNov 6, 2007
    …ll of the funds in his IRA, and Waddell & Reed issued nine checks to Dr . Amarasinghe totaling $179,368 . Dr . Amarasinghe endorsed each of these checks to Ms . Amarasinghe's attorney and delivered them to her . Dr . Amarasinghe and his spouse filed a joint 2002 Form 1040, U .S . Individual Income Tax Return, in 2003 .…
  2. 36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1961related by meaning
    ter refer only to section 1551, the provisions of which are as follows : SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
  3. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    r in the computation of the sec. 72(t) tax, her petition raised the issue whether she should have been subject to any additional tax under sec. 72(t). Sec. 402(e)(1) has been redesignated sec. 402(d) by the Unemployment Compensation Amendments of 1992, Pub. L. 102-318, sec. 521(a) and (b), 106 Stat. 290, 300-310, 313, …
  4. T.C. Summary Opinion 2005-173 — Keith Lamar Jones v. Commissioner
    IRCCourt RulingsNov 29, 2005
    …University of Arizona; he graduated in May 2004. In 2001, petitioner received a distribution of $30,368.86 from the 401(k) plan. He used the funds from the distribution to pay school expenses and to purchase his first home. At the time of the distribution petitioner had not reached 59½ years of age. 1 - 3 - Petitioner …
  5. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  6. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
  7. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024
    ), is treated as occurring on April 24, 2024. (F) Ownership by certain successors under section 368(a)(1)(F). For purposes of paragraph (c)(3)(vi)(A)( 3) of this section, the transferor corporation and the resulting corporation (as defined in § 1.368-2(m)(1)) in a reorganization described under section 368(a)(1)(F) (wh…
  8. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  9. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    Internal Revenue Service Index Nos.: 72.00-00, 101.00-00, 264.00-00 403.00-00, 368.00-00, 1502.00-00, 7702.00-00, 7702A.00-00 Number: 199916023 Release Date: 4/23/1999 Department of the Treasury P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Person to Contact: Telephone Number: Refer Reply To: CC:DOM:CORP:2-PL…
  10. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996related by meaning
    mount necessary to fund the benefits payable under section 415 determined at the time of the contribution in question. Citrus Valley Estates, Inc. v . Commissioner , 99 T.C. at 447. The dispute in these cases focuses on the amounts of benefits payable under section 415 determined at the time of the contributions in que…
  11. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    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…
  12. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    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…
  13. Treas. Reg. § 1.101-1(c)(2)(iv) — Exclusion from gross income of proceeds of life insurance contracts payable by reason of death.
    IRCRegulationsJul 9, 2026
    …(D) (D) The acquisition results from a transaction that qualifies as a reorganization under section 368(a) with respect to which the target C corporation and the acquiring C corporation each is a party to the reorganization (within the meaning of section 368(b));
  14. 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…
  15. 29 C.F.R. § 4044.58 — Tables used to determine expected retirement age.
    PBGCRegulationsJan 1, 2026
    …9 969 4,092 4,092 2034 990 990 4,182 4,182 2035 1,012 1,012 4,274 4,274 2036 or later 1,034 1,034 4,368 4,368 1 Applicable tables for valuation dates before 2026 are available on PBGC's website (www.pbgc.gov). 2 Table II-A. 3 Table II-B. 4 Table II-C.
  16. PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
  17. Treas. Reg. § 1.408-1(e) — General rules.
    IRCRegulationsMay 18, 2016related by meaning
    (e) (e) Community property laws. Section 408 shall be applied without regard to any community property laws.
  18. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981related by meaning
    Private Letter Ruling 7939003. (Private letter rulings have no precedential authority. Sec. 6110(j)(3).) In this ruling, respondent stressed that sec. 269 was meant to apply in those circumstances where allowance of a given benefit would be inconsistent with the scheme Congress was attempting to encourage in enacting a…
  19. 88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction
    IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
    tax-favored under the same country's laws) must be made in cash and must be based on income earned from employment or self-employment activities. See sections 219, 408, and 408A. Third, in appropriate fact patterns, the transaction viewed as a whole may be disregarded under relevant judicial doctrines, including the s…
  20. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    taxing IRA distributions. This amendment removes the legislative underpinnings for double taxation upon which respondent heavily relies in this case. In 1974, when Congress decided to include in income the distribution of excess contributions, it clearly and explicitly required such inclusion in both the language of s…