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83 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 29 C.F.R. § 4902.12(b) — Specific exemptions: Insider Threat and Data Loss Prevention.
    PBGCRegulationsJan 6, 2025
    …th the integrity of information which would otherwise be subject to privileges, see, e.g., 5 U.S.C. 552(b)(5), and which could interfere with other important law enforcement concerns, see, e.g., 5 U.S.C. 552(b)(7).
  2. 29 C.F.R. § 4902.13(b) — Specific exemptions: Legal case management.
    PBGCRegulationsJan 6, 2025
    … integrity of information which would otherwise be subject to legal privileges, see, e.g., 5 U.S.C. 552(b)(5), and which could interfere with other important law enforcement concerns, see, e.g., 5 U.S.C. 552(b)(7).
  3. T.C. Summary Opinion 2020-14 — Dale W. Laue & Alicia Laue v. Commissioner
    IRCCourt RulingsApr 20, 2020related by meaning
    om qualified retirement plans unless one of the exceptions set forth in section 72(t)(2) applies. Section 72(t) provides in pertinent part as follows: SEC. 72(t). 10-Percent Additional Tax on Early Distributions from Qualified Retirement Plans.-- (1) Imposition of additional tax.--If any taxpayer receives any amount fr…
  4. Treas. Reg. § 54.9802-4(f)(1)(ix) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover…
    IRCRegulationsAug 19, 2019
    …H employs 17 full-time employees and 10 part-time employees whose work site is in rating area 1 and 552 full-time employees whose work site is in rating area 2. For 2020, Plan Sponsor H offers its 17 full-time employees in rating area 1 a traditional group health plan and each of its 552 full-time employees in rating a…
  5. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    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…
  6. 29 C.F.R. § 4204.21(a) — Requests to PBGC for variances and exemptions.
    PBGCRegulationsSep 15, 2025
    … provide to the plan privileged or confidential financial information within the meaning of section 552(b)(4) of the Freedom of Information Act (5 U.S.C. 552), the purchaser or seller may request from the PBGC an exemption or variance from the requirements of section 4204(a)(1)(B) and (C) of ERISA. (a)(2) (2) Method of…
  7. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005related by meaning
    the deficiency in this case. With respect to petitioners' first contention, as noted earlier, section 72(t)(2) excepts from the additional tax certain categories of distributions. Petitioners agree that none of these categories apply to their fact situation. Instead, petitioners contend that, because of financial hards…
  8. U.S. Tax Court — John C. Armbrust v. Commissioner
    IRCCourt RulingsJan 19, 2010related by meaning
    from qualified retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C . Memo . 2 .005-124 (education expenses paid from a section .401(k)_ plan do not qualify for the exception . of ,section 72(t) (2) (E))- ; Milner v . Commissioner , T .'C .` .Memo . 2004-111 (no "umbrell a hardship exception" .for a distr…
  9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    husband only. The notices of deficiency also determined accuracy-re lated penalties under section 6662, but respondent has conceded the penalties . 3 [* 3 ] After a corporate reorganization in 2004, TEOHC informed petitioner that it wished to buy out his interests. Following lengthy negotiations , TEOHC a greed to pay…
  10. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    at trial that he had filed a return for 2012 showing tax due. Although his 2013 account transcript r eflects a withholding credit of $320 , petitioner has neither argued nor shown that his 2013 withholding equaled or exceeded the amount of tax shown on his 2012 return. As for 2014, petitioner’s required annual payment …
  11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ncrete & Supply, LLC , 566 U.S. 478, 483 (2012) (citing John R. Sand & Gravel Co. v. United States, 552 U.S. 130, 139 (2008)). “ [ S ] tare decisis in respect to statutory interpretation has ‘special force,’ for ‘Congress remains free to alter what we have done.’” John R. Sand & Gravel Co. , 552 U.S. at 139 (quoting Pa…
  12. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
    IRCCourt RulingsJul 8, 2020related by meaning
    346, 347 (requiring self-certification that the rollover contribution was made "as soon as practicable" after the obstacle preventing the rollover was removed). Under these facts, declining to waive the 60-day requirement is not against equity or good conscience, and petitioner is therefore taxable on the full $54,500 …
  13. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    T.C. Memo. 1997-346 UNITED STATES TAX COURT WILLIAM L. REESE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18442-95. Filed July 29, 1997. 1. Held : P is taxable on a pension plan distribution because he failed to roll over that distribution within the 60-day period prescribed by sec. 402(a)(5)…
  14. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  15. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …tment for shareholder-employees of professional service corporations. Comm, on Finance, S. Rept. 91-552, Amendment (in the nature of a substitute) to H.R. 13270, p. 509. This provision was deleted on the Senate floor from the final Senate version of H.R. 13270. 115 Cong. Rec. 37922-37931 (1969). It is apparent from the…
  16. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  17. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    … 1,736,964 Total disbursements 29,309,726 34,968,999 36,063,764 Net increase (decrease) of assets 5,552,678 1,895,497 6,886,506 Assets at end of period 5,552,678 7,448,175 14,334,681 Reserves for Incurred But Unpaid Claims
  18. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012related by meaning
    CLC T.C. Memo. 2012-344 UNITED STATES TAX COURT KARL E. CROSS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6009-09. Filed December 13, 2012. Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner. Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent. MEMORANDUM OPIN…
  19. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984
    …87, 643-646, 1969-3 C.B. 10, 101-102; H. Rept. 91-413 (1969), 1969-3 C.B. 200, 296-298: S. Rept. 91-552 (1969), 1969-3 C.B. 423, 550-552. The 7-year forward averaging provisions demonstrated that Congress was still concerned with the problem of bunched income.
  20. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    023.94 81,023.94 81,023.94 81,023.94 64,819.15 For taxable year ended November 26, 1986, respondent determined a second-tier deficiency of $6,481,915. The issues presented for our consideration all involve whether a sale of real estate by petitioners to an employee stock ownership plan was a prohibited transaction givi…