IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
IRCCourt RulingsJul 29, 1997related by meaning
one taxable year; at
best, petitioner's assertion undermines the characterization of
the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case.
c. Frozen Deposit Rule
Finally, although it is not clear whether petitioner relies
on the special rule for frozen deposits f…
IRCCourt RulingsJan 27, 1998
…ary of Labor pursuant to the authority
transferred to the Secretary of Labor as provided in
Section 102 of this Plan.
-21-
12
In making his argument, petitioner relies on ERISA sec.
502(i), 29 U.S.C. sec. 1132(i) (1988), which provides that the
Secretary of Labor may assess a civil penalty against a party in
interest. …
IRCCourt RulingsJun 17, 1997
…rmation:
- 50 -
1990
1991
1992
1993
1994
Fund value at yearend $300,000 $304,342 $317,443 $326,944 $338,487
Policy values-0-303,424 316,513 327,064 338,607
Surrender value N/A 240,440 255,413 269,293 283,222
Additional contribution available-0-17,312 29,863 44,164 57,460
Date of report 3/06/91 11/16/92 2/23/94 8/15/94 …
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
161 T.C. No. 6 — Estate of James E. Caan, Deceased, Jacaan Administrative Trust, Scott Caan, Trustee, Special
Administrator v. Commissioner IRCCourt RulingsNov 14, 2023
… which included a mental health
issue, and asked for a waiver of the 60-day rollover period. Id. at 338.
13
An employees’ trust is a “trust created or organized in the United States”
that is “part of a stock bonus, pension, or profit-sharing plan of an employer for the
exclusive benefit of his employees or their benefi…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsOct 11, 1995related by meaning
tion that petitioners
are liable for the 10-percent additional tax imposed by section
72(t).
Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph
(1), which imposes the tax, provides in relevant part as follows:
(1) Imposition of Additional Tax.--If an…
FAB 2026-02 — Temporary Enforcement Policy Regarding Pension Benefit Statements Pursuant to ERISA § 105(a)(2)(E) ERISADOL Field Assistance BulletinsDec 31, 2025
…ent Policy Regarding Pension Benefit Statements
Pursuant to ERISA § 105(a)(2)(E)
Background
Section 338(a) of the SECURE 2.0 Act of 2022 (SECURE 2.0) amended section 105(a)(2) of
ERISA by adding subparagraph (
E), which mandates the disclosure of certain pension
benefit statements in paper format. Under subparagraph (E…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…n & Loyalty Obligations + $4,762,239 to prepare the written statement of all material facts + 2,085,338 to prepare and send disclosures) ≉ $8,929,550. The cost in subsequent years is attributable to the $2,085,338 to prepare and send disclosures. Note that the total value may not equal the sum of the parts due to round…
IRCCourt RulingsDec 11, 2003related by meaning
f section 6501,
1
section 6651(a)(1),
2
- 37 -
2
(...continued)
(2003) ; Janpol v. Commissioner
, 102 T.C. 499, 503, 505 (1994);
Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, aff…
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…sic level price of these five products, the Department assumes that it would cost $28.2 per month ($338.4 per year) to subscribe. Assuming 7,392 plans would purchase this type of product, the Departments estimates that the aggregate costs would total an estimated $2.5 million (7,392 plans * $338.40).
Back to Citation
1…
IRCCourt RulingsJan 16, 2002related by meaning
cts and circumstances, it is
inequitable to hold the individual liable for any unpaid tax
or any deficiency (or any portion of either) attributable to any item for which relief is not available under the
preceding sentence, the Secretary may relieve such
individual of such liability. .
Petitioner's request for relief r…
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
… employer and its religious employees.
Real Alternatives,
150 F. Supp. 3d 419,
affirmed by
867 F.3d 338 (3d Cir. 2017). One member of the appeals court panel in
Real Alternatives
v.
Sec'y of HHS
dissented in part, stating he would have ruled in favor of the individual employee plaintiffs under RFRA. 867 F.3d 338, 367 (…
IRCCourt RulingsJul 24, 1991related by meaning
…ion by sec. 1011A(b)(8)(A) of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3473, does not affect the instant case.]
Sec. 514 of ERISA.
See, e.g., American Telephone and Telegraph Co. v. Merry, 592 F.2d 118 (2d Cir. 1979); Cody v. Riecker, 594 F.2d 314 (2d Cir. 1979).
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
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…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…files/pdf/205066/ACAWomenHealthIssueBrief.pdf.
Back to Citation
55. See, for example, 29 U.S.C. 1022, 1024(b), 29 CFR 2520.102-2, 102-3, & 104b-3(d), and 29 CFR 2590.715-2715.
See also45 CFR 147.200 (requiring disclosure of the “exceptions, reductions, and limitations of the coverage,” including group health plans …
ERISARegulationsJan 1, 2017
…st distributed summary plan description (or updated summary plan description), described in section 102 of the Act, and the next occurring applicable date described in paragraph (b)(1) of this section, for purposes of the requirement to furnish the updated summary plan description to each participant, and to each benef…
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…