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21. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979
    …ild was in the eighth grade in school. The trustee, therefore, did not pay any benefits in 1974 and 1975. Nevertheless, Citrus contributed $16,000 in 1974 and $34,000 in 1975. It deducted those amounts as “Other Deductions” in the respective Federal income tax return for each year. McElwee and Smith did not include any…
22. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    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 .…
23. 81 FR 21181 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit Plans and Broker-De…
    ERISAFinal Rules (FR)Apr 8, 2016
    …ry standards, nor accountable under ERISA or the Code for imprudent, disloyal, or biased advice. In 1975, the Department issued a regulation, at 29 CFR 2510.3-21(c)(1975), defining the circumstances under which a person is treated as providing “investment advice” to an employee benefit plan within the meaning of ERISA …
24. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982
    …se named were employed by Plastic from the date of its incorporation through at least September 30, 1975 (i.e., all were with the company for at least 1 full plan year), and all were participants in the plan. During the period September 15, 1974, through December 31, 1974, Donald R. Seifel, Sr., received salary from th…
25. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996related by meaning
    event the diversion of retirement savings for nonretirement purposes and to recapture a measure of the tax benefits provided by the deferral of income tax through retirement plans. At the same time, Congress recognized that it was appropriate to provide, under limited circumstances, an exemption from the tax for certai…
26. 68 T.C. 366 — Lozano, Inc. v. Commissioner
    IRCCourt RulingsJun 9, 1977
    …dustries, Inc. v. Commissioner, 64 T.C. at 907. See also Coker Pontiac, Inc. v. Commissioner, T. C. Memo. 1975-305 (held, for purposes of Rev. Rul. 71-38, 1971-1 C.B. 130, informal notice sufficient). See also Coker Pontiac, Inc. v. Commissioner, T. C. Memo. 1975-305; Misceramic Tile, Inc. v. Commissioner, T. C. Memo. …
27. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
28. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
29. Treas. Reg. § 1.414(f)-1(d) — Definition of multiemployer plan.
    IRCRegulationsSep 9, 2016
    …tions made under the plan for each of the years 1970, 1971, and 1972. For the years 1973, 1974, and 1975, U contributes 70 percent and V and W each contribute 15 percent of the total contributions made under the plan for each year. The plan is a multiemployer plan under section 414(f) and this section for 1975 because …
30. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
31. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016related by meaning
    ple, Deputy Commissioner for Services and Enforcement. Approved: April 29, 2016. Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy). Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011) [1] Section 20…
32. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993related by meaning
    aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
33. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ontributions and earnings within an individual account, grew substantially, from just 26 percent in 1975 to 78 percent in 2020.[163] By 2020, 94 percent of active participants in defined contribution plans had responsibility for directing the investment of some or all of their ( printed page 75915) account balances.[16…
34. 74 T.C. 1106; 2 Employee Benefits Cas. (BNA) 2385 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsAug 26, 1980
    …coverage under the plan discriminated in favor of the prohibited group. The letters of February 24, 1975, notified petitioners of their right of appeal to the National Office of the Internal Revenue Service. On March 31, 1975, petitioners were granted an extension of time to file such appeal until April 9, 1975. On Apr…
35. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
36. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
37. 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, 2016
    …vestment advice” to an employee benefit plan within the meaning of ERISA section 3(21)(A)(ii) (the “1975 regulation”).[5] The 1975 regulation narrowed the scope of the statutory definition of fiduciary investment advice by creating a five-part test for fiduciary advice. Under the 1975 regulation, for advice to constitu…
38. 81 FR 21002 — Best Interest Contract Exemption
    ERISAFinal Rules (FR)Apr 8, 2016
    …vestment advice” to an employee benefit plan within the meaning of ERISA section 3(21)(A)(ii) (the “1975 regulation”).[6] The 1975 regulation narrowed the scope of the statutory definition of fiduciary investment advice by creating a five-part test for fiduciary advice. Under the 1975 regulation, for advice to constitu…
39. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
40. Treas. Reg. § 1.72-17A(ii)(2)(iv)(A) — Special rules applicable to employee annuities and distributions under deferred compensation plans to self-employed individuals and owner-employees.
    IRCRegulationsMar 14, 2019
    …)(A) of this subparagraph does not apply to the contributions made by X on behalf of A for 1976 and 1975 ($7,500 each year, totaling $15,000) nor to the increments in value attributable to those contributions ($900 for 1976 and $4,000 for 1975, totaling $4,900), because A was not an owner-employee with respect to these…