IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsDec 23, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respo…
IRCCourt RulingsMay 19, 2011related by meaning
treated as a gift, dividend,
contribution of capital, payment of compensation, or other
payment depending on the substance of the transaction. Section 7872 applies to a transaction that is a loan subject to a belowmarket interest rate and is described in one of several
enumerated categories. Sec. 7872(c) (1), (e) (1), …
T.D. 9325 — Final regulations under section 401 of the Code provide rules permitting in-service distributions to be made to a participant from a pension plan upon the part… IRCTreasury DecisionsJun 11, 2007related by meaning
ovide guidance regarding an employer’s request to use its own plan-specific mortality tables.
ADMINISTRATIVE
Announcement 2007-57 Announcement 2007-57 This document contains corrections to final regulations (T.D. 9319, 2007-18 I.R.B. 1041) regarding the limitations of section 415 of the Code, including updates to the r…
T.D. 9130 — Final regulations concern required minimum distributions under section 401(a)(9) of the Code for defined benefit plans and annuity contracts providing benefits… IRCTreasury DecisionsJun 28, 2004related by meaning
till alive, without regard to any increases in annuity payments after the date of determination, and taking into account any remaining period certain. (4) Acceleration of payments means a shortening of the payment period with respect to an annuity or a full or partial commutation of the future annuity payments. An incr…
T.D. 9419 — Final regulations under section 430 of the Code provide mortality tables to be used in determining present value or making any computation for purposes of appl… IRCTreasury DecisionsOct 6, 2008related by meaning
ster, NY, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.
ADMINISTRATIVE
Announcement 2008-87 Announcement 2008-87 This document announces the discontinuation of the publication of Legislative Cumulative Bulletins because this material is readily available on various websites much ea…
T.D. 9987 — These regulations provide guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These regulations pr… IRCTreasury DecisionsFeb 5, 2024related by meaning
o §1.411(d)-3(a) apply to plan amendments adopted on or after January 19, 2024.
Special Analyses
1. Regulatory Planning and Review – Economic Analysis Pursuant to the Memorandum of Agreement, Review of Treasury Regulations under Executive Order 12866 (June 9, 2023), tax regulatory actions issued by the IRS are not subj…
80 FR 22004 — Proposed Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Em… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
y to enable the persons described in paragraph (e) of this exemption to determine whether the conditions of this exemption have been met, except that: (1) No party other than the broker-dealer engaging in the covered transaction shall be subject to the civil penalty which may be assessed under section 502(i) of the Act…
ERISACourt RulingsJan 20, 1998related by meaning
over its proceeds,
including accrued interest, into CD No. 11813-17572 in the amount
of $249,683.99 issued by TC; this CD was pledged as collateral on Loan No. 1310001 on October 15, 1987.10 Ex. C10 & C11. On
October 19, 1987, CD No. 11813-17493 matured, and Respondents
rolled its proceeds over into CD No. 11813-17579 …
81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
sultant, insurance company, or investment company principal underwriter engaging in the transaction must maintain records of the
( printed page 21170) transaction for six years, accessible for audit and examination. A commenter on this provision recommended that the word “reasonably” be inserted prior to the term “acce…
IRCCourt RulingsMay 15, 1978related by meaning
as if it were a single employer plan. H.R. Conf. Rept. 93-1280, 93d Cong., 2d Sess. 271 (1974), reprinted in U.S. Code Cong. & Adm. News 5052 (1974). On June 30,1976, the Department of Labor issued ERISA Technical Release (ETR) 2003 which set forth seven conditions which a plan was required to satisfy to determine ser…
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…
IRCCourt RulingsApr 2, 2024related by meaning
d ending
on the date which is 60 days after the latest incident date so specified
“shall be disregarded in the same manner as a period specified under [ section 7508A(a)].” Section 7508A(d)(2)(A) defines a “qualified
taxpayer” to include an individual whose principal residence is located
in a disaster area. Section 750…
IRCCourt RulingsJul 24, 1991related by meaning
ortion of the distribution go to Yolanda.
We hold for respondent on this issue.
To reflect the foregoing,
Decision will be entered for the respondent. Petitioner concedes that, due to an error on his 1983 tax return, the capital gain portion of the distribution in issue which was shown on line 1 of his Form 4972 (Speci…
80 FR 22010 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and B… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
ployee Benefits Security Administration, (Attention: D-11850), U.S. Department of Labor, 122 C St. NW., Suite 400, Washington, DC 20001.
Instructions. All comments must be received by the end of the comment period. The comments received will be available for public inspection in the Public Disclosure Room of the Employ…
T.D. 9223 — Final regulations under section 402 of the Code address the amount includible in a distributee’s income when life insurance contracts are distributed by a qual… IRCTreasury DecisionsSep 26, 2005related by meaning
he form may also be used to furnish the donor of a qualified vehicle with a contemporaneous written acknowledgment.
EMPLOYEE PLANS
T.D. 9220 T.D. 9220 Temporary and proposed regulations under section 408A of the Code provide guidance concerning the tax consequences of converting a non-Roth IRA annuity to a Roth IRA. Th…
Notice 2005-92 — Distributions; recontributions; loans; Katrina Emergency Tax Relief Act of 2005 (KETRA). This notice describes various aspects of sections 101 and 103 of KETRA… IRCNoticesDec 19, 2005related by meaning
-42 I.R.B. 723, which defines taxpayers affected by Hurricane Katrina and designates disaster areas for purposes of the relief provided under § 7508A. [3] Form 8915 is expected to be available soon.
[4] The Department of Labor has advised the Department of the Treasury and the Service that it will not treat any person …
IRCCourt RulingsApr 11, 2006related by meaning
ecause you forfeited your right to repay
the loan in full, effective 09/16/02, a taxable distribution in the amount of $15,462.60 has been declared in connection with the unpaid principal and unpaid interest to 09/16/02, on * * * [petitioner's $15,462.60]
loan.
Both September 23, 2002 letters further advised petitioner…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
to comply with protective conditions designed to ensure prudent advice and avoid the harmful impact of dangerous conflicts of interest.
Recordkeeping Section IV provides that the Financial Institution must maintain for a period of six years following the covered transaction records demonstrating compliance with this e…