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Go to T.C. Summary Op. 2014-106 (not yet in the library — opens the official source)
81 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 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…
  2. Notice 2014-73 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for October 2014 used under § 417(e)(3)(D), the …
    IRCNoticesDec 1, 2014
    verages applicable for November 2014 adjusted for the HATFA applicable percentages of the corresponding 25-year average segment rates, are as follows: For Plan Years Beginning In Adjusted 24-Month Average Segment Rates, Based on the HATFA Applicable Percentage of 25-Year Average Rates Applicable Month First Segment Sec…
  3. Notice 2014-78 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2014 used under § 417(e)(3)(D), the…
    IRCNoticesDec 29, 2014
    verages applicable for December 2014 adjusted for the HATFA applicable percentages of the corresponding 25-year average segment rates, are as follows: For Plan Years Beginning In Adjusted 24-Month Average Segment Rates, Based on the HATFA Applicable Percentage of 25-Year Average Rates Applicable Month First Segment Sec…
  4. Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect…
    IRCRevenue RulingsJun 23, 2014related by meaning
    …to such practice and prescribe the disciplinary sanctions for violating the regulations. Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members. Notice 2014–39 Notice 2014–…
  5. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  6. 29 C.F.R. § 4022.27(e) — Phase-in of guarantee of unpredictable contingent event benefits.
    PBGCRegulationsJan 1, 2017
    …ry issued a certification stating that the plan's adjusted funding target attainment percentage for 2014 is 58%. Therefore, the plan restricts payment of the unreduced early retirement benefit payable with respect to the shutdown on April 15, 2014.(C) On August 15, 2014, the plan sponsor makes an additional contributio…
  7. Rev. Rul. 2014-34 — 2015 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2015 are provided for use in …
    IRCRevenue RulingsDec 22, 2014
    INCOME TAX Rev. Rul. 2014–29 Rev. Rul. 2014–29 Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning January 1, 2015, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for the underpayments,…
  8. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015
    … = 0.160 = 16.0 percent (b) Same facts as (a), except that M manages the portfolio through July 15, 2014, and, in addition, resumes management of the portfolio on November 10, 2014, through the end of the year. The additional relevant valuation dates and portfolio values are: Dates Market value ($ millions) July 15, 20…
  9. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    nd to the extent not discussed herein we conclude that they are irrelevant, moot, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
  10. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  11. Notice 2014-50 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for August 2014 used under § 417(e)(3)(D), the 2…
    IRCNoticesSep 29, 2014
    erages applicable for September 2014 adjusted for the HATFA applicable percentages of the corresponding 25-year average segment rates, are as follows: For Plan Years Beginning In Adjusted 24-Month Average Segment Rates, Based on the HATFA Applicable Percentage of 25-Year Average Rates Applicable Month First Segment Sec…
  12. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    we conclude that petitioner did not substantially prevail with respect to the most significant issue, we need not address whether respondent's - 13 - position was substantially justified. Accordingly, we will deny petitioner's motion. We have considered the remaining arguments of both parties for results contrary to th…
  13. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    appears on dozens of other documents in the record. In any event petitioner offered no plausible explanation about where the money went if not to him. 4We do not believe that respondent was obligated to concede the inapplicability of the section 72(t) additional tax or the nontaxability of $737 in miscellaneous income.…
  14. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    .............................. 116 2. Events .......................................... 117 3. Analysis and holding............................... 118 X. Period 15: July 27, 2009, through August 9, 2010. . . . . . . . . . . . . 119 1. Introduction...................................... 119 2. Events ....................…
  15. T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr…
    IRCTreasury DecisionsDec 9, 2013related by meaning
    INCOME TAX Rev. Rul. 2013–26 Rev. Rul. 2013–26 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2013. EMPLOYEE PLANS T.D. 9641 T.D. 9641 These final…
  16. 78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage
    IRCProposed Rules (FR)Proposed Jan 2, 2013
    …13 through December 31, 2013 (six months), followed by an administrative period ending on March 31, 2014. However, an employer with a fiscal plan year beginning on July 1, 2014 must use a measurement period that is longer than 6 months in order to comply with the requirement that the measurement period begin no later t…
  17. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    …scribed any expenditure that would qualify for a 2013 deduction or credit. In opposing a motion for summary judgment, the nonmovant may not rest upon the mere allegations or denials in his pleadings but instead must set forth specific facts showing that there is a genuine dispute for trial. Rule 121(d); see Sundstrand …
  18. 81 FR 95911 — Mortality Tables for Determining Present Value Under Defined Benefit Pension Plans
    IRCProposed Rules (FR)Proposed Dec 29, 2016
    mortality tables that are referred to as the RP-2014 mortality tables). The RP-2014 Mortality Tables Report, as revised November 2014, is available at www.soa.org/​Research/​Experience-Study/​pension/​research-2014-rp.aspx. At the same time, RPEC issued a companion study of mortality improvement, referred to as the Mor…
  19. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  20. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    …nse of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burden of proving that there is no genuine issue…