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92 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    …k to Citation 122.  Values calculated as follows: Year 1—397,749 notices × 2/60 clerical hours = 13,258 burden hours. $63.45 clerical worker wage × 13,258 burden hours = $841,239. Subsequent years: 736,825 notices × 2/60 clerical hours = 24,561 burden hours. $63.45 clerical worker wage × 25,572 burden hours = $1,558,38…
  2. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    he penalties in docket Nos. 2545-94 and 9230-94; an appropriate decision for respondent will be entered in docket No. 5754-94 as to the deficiency and the addition to tax under section 6651(a)(1) and for petitioner with respect to the penalty .
  3. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    rs, as it was required to do. See Frederick Vietor & Achelis v. Salt’s Textile Mfg. Co., 26 F.2d 249, 255 (D. Conn. 1928); O.D. 419, 2 C.B. 60 (1920). What is more, petitioner claimed its foreign tax credit in dollars. It would thus appear that petitioner’s position should be rejected, since section 905(c) speaks in te…
  4. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024
    …1 Subsequent years Burden hours Equivalent burden cost Burden hours Equivalent burden cost Legal 36,258 $6,008,343 36,258 $6,008,343 Senior Executive Staff 67,467 13,375,426 67,467 13,375,426 Total 103,726 19,383,769 103,726 19,383,769 1.5 Costs Associated With Written Policies and Procedures Under the original exempti…
  5. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    …15(b) Failures and Correction of Overpayments (Defined Benefit Plans) 252 .06 § 401(a)(17) Failures 258 .07 Correction by Amendment 258 SECTION 3. EARNINGS ADJUSTMENT METHODS AND EXAMPLES 260 .01 Earnings Adjustment Methods 260 .02 Examples 263 PART I. INTRODUCTION TO EMPLOYEE PLANS COMPLIANCE RESOLUTION SYSTEM SECTION…
  6. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002related by meaning
    stribution should not be subject to the 10-percent additional tax because she is entitled to rely on the advice of respondent’s representatives. - 7 - Although we cannot be certain whether petitioner misunderstood the advice she received or whether erroneous advice was rendered, that distinction does not make a differe…
  7. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  8. 90 FR 2645 — Catch-Up Contributions
    IRCProposed Rules (FR)Proposed Jan 13, 2025
    … The proposed revisions and additions to § 1.414(v)-1 would mainly reflect changes made by sections 109 and 117 of the SECURE 2.0 Act. In particular, the revisions to § 1.414(v)-1 would: (1) reflect the increased applicable dollar catch-up limits permitted under sections 109 and 117 of the SECURE 2.0 Act (along with up…
  9. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
  10. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …8 1,265 Rent/lease 20,097 20,097 20,097 --- Legal and professional 2,234 2,234 2,234 --- Interest 3,109 3,109 3,109 --- Insurance 10,634 10,634 10,634 --- Commissions and fees 112,432 112,432 112,432 --- i. Other Expenses On brief respondent concedes that petitioners have substantiated all but $170 of this reported exp…
  11. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997
    …and to make improvements to petitioners' residence, resulting in the outstanding loan balance of $9,109.93 at the time of the gross distribution. A statement of petitioner's pension plan account as of April 30, 1990, the effective date of petitioner's termination from the plan, indicated that there was an attached chec…
  12. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  13. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019
    …, rev'd on other grounds, 514 F.3d 1119 (10th Cir. 2008); Hull v. Commissioner, T.C. Memo. 2015-86, 109 T.C.M.
  14. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  15. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    … services revenue when translated under § 1.987-3(c)(1) at the yearly average exchange rate equals $109.09 (¥12,000 × ($1/¥110)) = $109.09). The ¥2,000 of expenses translated at the same yearly average exchange rate equals $18.18 (¥2,000 × ($1/¥110) = $18.18). Thus, Japan Branch's net income translated into dollars equ…
  16. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    statement within 90 days. Therefore, aRespondent argues that since the TSP did not accept petitioner's late August payment, petitioner never made this payment. We base our holding on.the fact athat petitioner failed to pay the remaining balance before the end of the cure period or notify the TSP of his reinstatement. -…
  17. 89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCFinal Rules (FR)Jun 28, 2024
    …al and attach an appraisal summary to the return. See Hewitt v. ( printed page 54303) Commissioner, 109 T.C. 258, aff'd without published opinion,
  18. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    … services revenue when translated under § 1.987-3(c)(1) at the yearly average exchange rate equals $109.09 (¥12,000 × ($1/¥110)) = $109.09). The ¥2,000 of expenses translated at the same yearly average exchange rate equals $18.18 (¥2,000 × ($1/¥110) = $18.18). Thus, Japan Branch's net income translated into dollars equ…
  19. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    112 T.C. No. 6 UNITED STATES TAX COURT GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18999-97. Filed February 22, 1999. H and W, who were both disqualified persons within the meaning of sec. 4975, I.R.C., borrowed $340,000 from the qualified pension plan…
  20. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    an were part of a split-dollar life insurance arrangement. We hold they were; 3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's income in a single, corporate-level proceeding. However, the Small Business Job Protection Act…