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81 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20% 5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference to any SFRs. Even if it did, the literal transcript does not establish that the requ…
  2. 80 FR 71936 — Interpretive Bulletin Relating to State Savings Programs That Sponsor or Facilitate Plans Covered by the Employee Retirement Income Security Act of 1974
    ERISAFinal Rules (FR)Nov 18, 2015
    …olds Approaching Retirement Have Low Savings (GAO Report-15-419) (available at www.gao.gov/​assets/​680/​670153.pdf). Also see GAO's September 2015 Report-15-566, RETIREMENT SECURITY—Federal Action Could Help State Efforts to Expand Private Sector Coverage (available at www.gao.gov/​assets/​680/​672419.pdf). Back to Ci…
  3. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    sonable compensation and therefore not deductible under section 162 (and thereby section 404), the 10% section 4972 excise tax applies to that extent. V. Section 6651(a)(1) and (2) Additions to Tax Respondent contends that the corporation is liable for section 6651(a)(1) failure to file additions to tax of $10,050.95 a…
  4. 79 FR 78578 — Summary of Benefits and Coverage and Uniform Glossary
    IRCProposed Rules (FR)Proposed Dec 30, 2014
    …,885 SBC with Coverage Examples—Participants and Beneficiaries: Upon Application or Eligibility 222,680 111,340 1,855.67 54,928 Upon Renewal 17,129,262 8,564,631 142,743.85 4,225,218 Beneficiaries Living Apart 33,000 33,000 550.00 16,280 Sub-Total 17,384,942 8,708,971 145,150 4,296,426 Uniform Glossary 428,232 428,232 …
  5. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
  6. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
  7. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …cy (certificate No. 5076058) on the life of Dr. Hirshkowitz, age 57. The first-year premium was $48,680, and the cost of insuring Dr. Hirshkowitz for that year was $9,475.15. The Lakewood Plan paid the first-year premium, and, at the end of that year, the conversion credit balance was
  8. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
  9. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    he earned less than other dentists in the area but the best evidence of the value of his personal services is profit he derived from his own practice. As a final issue, we must decide whether the 5-percent addition to tax under section 6653(a) is applicable. In his statutory notice of deficiency, the Commissioner made …
  10. REG-117270-25 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Mar 23, 2026
    … percentile $1,000 at birth 2,980 6,180 13,800 $1,000 at age 1 2,860 5,690 11,990 $1,000 at age 2 2,680 4,920 10,040 $1,000 at age 3 2,400 4,750 9,030 $1,000 at age 4 2,150 4,260 8,040 $1,000 at age 5 2,020 3,990 7,110 $1,000 at age 6 1,770 3,620 6,350 $1,000 at age 7 1,660 3,280 5,380 $1,000 at age 8 1,680 3,150 4,670…
  11. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    ning qualification vel non, the Court will follow the settled case law of this and other courts. 26 C.F.R. sec. 601.201(1)(5) provides, in part, that: "Except in rare or unusual circumstances, the revocation or modification of a ruling will not be applied retroactively with respect to the taxpayer to whom the ruling wa…
  12. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
  13. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    s. 601.201(a)(2) and (3), 601.201(1)(5), and 601.201(m), Statement of Procedural Rules; Myron v. United States, 382 F.Supp. 590, 597 (C.D. Cal. 1974). In analogous situations, when there have been similar material changes in the facts on which a ruling was based, the courts have upheld the Commissioner’s authority to r…
  14. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    8 years on June 10, 2016. That notice was issued timely because, as of 3 The opposite presumption may apply for certain statutes affect ing procedural rights. See Chenault , 37 F.3d at 53 8. Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 8…
  15. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    tive history to conclude that the revision advocated by petitioners was not contemplated by Congress when it enacted section 6501(1)(1) (then (n)(1)). Finally, although petitioners’ argument has not been addressed expressly by this Court, our interpretation of section 6501(e)(3) is consistent with our precedents. In Ru…
  16. Treas. Reg. § 1.72-16(c)(3) — Life insurance contracts purchased under qualified employee plans.
    IRCRegulationsJul 26, 2016
    …,000). Accordingly, the portion of each annual installment which is subject to section 101(d) is $1,680 ( 14/25 of $3,000), of which $1,400 ( 1/10 of $14,000) is excludable under section 101(a), and the remaining $280 is includible in the gross income of the beneficiary. However, if the beneficiary is a surviving spous…
  17. IRCRegulationsMar 14, 2019related by meaning
    [Reserved]
  18. IRCRegulationsSep 17, 2024
    …mployee B (the HCE with the highest ADR) are reduced by $1,280 in order to reduce his ADR to 6% ($7,680/$128,000), which is the ADR of Employee A.(iii) Because the ADP of the HCEs determined after the $1,280 reduction to Employee B still exceeds 5%, further reductions in elective contributions are necessary in order to…
  19. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. Both sides have dealt with the status of the 32-page document as a tax return but only for purposes of the sec. 6651(a) issue presented to us. Under the circumstances, w…
  20. Treas. Reg. § 1.415(d)-1(a)(7) — Cost-of-living adjustments.
    IRCRegulationsSep 9, 2016
    …b)(1)(A) is $185,000, and the compensation limit applicable to X under section 415(b)(1)(B) is $206,680 ($200,000 multiplied by the annual adjustment factor of 1.0334). Accordingly, the adjustment to X's benefit satisfies the safe harbor for cost-of-living adjustments under paragraph (a)(5) of this section if, after th…