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98 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. Notice 2022-33 — Notice 2022-33 extends the deadlines for amending a retirement plan or IRA to reflect the provisions of Division O of the Further Consolidated Appropriations A…
    IRCNoticesAug 22, 2022
    …lect certain provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), and section 104 of Division M of the Further Consolidated Appropriations Act, 2020, known as the…
  2. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  3. Notice 2021-31 — This notice provides guidance on issues relating to the application of § 9501 of the American Rescue Plan Act of 2021 (the ARP), which provides temporary premi…
    IRCNoticesJun 7, 2021
    …d wages under § 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. 116-136, 134 Stat. 281 (March 27, 2020), as amended by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), which was enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L. 116-2…
  4. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  5. Notice 2020-51 — This notice provides guidance relating to the waiver in 2020 of required minimum distributions (RMDs) from certain retirement plans and IRAs due to the amendme…
    IRCNoticesJul 13, 2020
    … plans under section 2203 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub.L. 116-136, 134 Stat. 281 (2020). In particular, the notice: permits rollovers of waived required minimum distributions (RMDs) and certain related payments, including an extension of the 60-day rollover period for certain d…
  6. T.C. Memo. 2016-228 — Suzanne D. Oster Ozimkoski v. Commissioner
    IRCCourt RulingsDec 19, 2016
    …e tax required to be shown on the tax return or $5,000. Sec. 6662(d)(1)(A); Higbee v. Commissioner, 116 T.C. at 448. As stated supra p. 17, under section 7491(c) the Commissioner bears the burden of production with regard to penalties. Higbee v. Commissioner, 116 T.C. at 446. Once the Commissioner has met the burden of…
  7. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    ethod is $116. The amount that would be paid under Medicare for the emergency service, excluding any copayment or coinsurance for the service, is $80. (ii) Conclusion. In this Example 5, the plan is responsible for paying $92.80, 80% of $116. The median amount among those agreed to for the emergency service is $115 and…
  8. 71 T.C. 332 — Brownholtz v. Commissioner
    IRCCourt RulingsDec 4, 1978related by meaning
    that the Internal Revenue Code requires such tax-free recovery is therefore in error, and is no basis for declaring any section 72 regulation invalid. Petitioner makes various constitutional arguments against the result reached by the Commissioner, all of which are unpersuasive. Petitioner contends that retroactive app…
  9. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …rtion of an underpayment for which the taxpayer shows reasonable cause and good faith. See Higbee , 116 T.C. at 448. Reasonable cause is determined case by case, considering all pertinent facts and circumstances. Treas. Reg. § 1.6664- 4(b)(1). The inquiry focuses on whether the taxpayer exercised ordinary business care…
  10. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  11. Treas. Reg. § 1.401(a)(9)-9(d) — Life expectancy and distribution period tables.
    IRCRegulationsSep 17, 2024
    …3.1 3.1 3.0 3.0 2.9 114 3.6 3.5 3.3 3.2 3.1 3.0 3.0 2.9 2.9 115 3.6 3.4 3.3 3.2 3.1 3.0 2.9 2.9 2.9 116 3.5 3.3 3.2 3.1 3.0 2.9 2.8 2.8 2.8 117 3.4 3.3 3.1 3.0 2.9 2.8 2.7 2.7 2.7 118 3.3 3.1 3.0 2.8 2.7 2.6 2.6 2.5 2.5 119 3.1 2.9 2.8 2.6 2.5 2.4 2.4 2.3 2.3 120+ 3.0 2.8 2.6 2.5 2.3 2.2 2.1 2.1 2.1 Table 3 to Paragrap…
  12. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468. Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
  13. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …ctive interest rate of 5.5% for 2009. Accordingly, the prefunding balance used for this purpose is $116,050 [($125,000 − $15,000 deemed reduction) × 1.055].(iii) The fair market value of plan assets used for the December 31, 2010, valuation is $883,950 ($1,000,000 − $116,050). Example 11.(i) The facts are the same as i…
  14. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    settlement agreement is not a qualified domestic order, and Mr. Ahmad is not an alternate payee, the exception in section 72(t)(2)(C) is inapplicable. In light of the foregoing, the Court holds that petitioners are liable for the 10-percent additional tax imposed under section 72(t). Reviewed and adopted as the report …
  15. Notice 2024-3 — 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans
    IRCNoticesJan 8, 2024
    …000 or 150% of the regular catch-up limit for 2025, indexed for inflation. 10. Section 415: Section 116 of the SECURE Act amends section 415(c) of the Code to treat difficulty of care payments that are excluded from gross income as compensation for determining retirement contribution limitations. Notice 2020-68 provide…
  16. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    been finalized. Moreover, even if the proposed regulation were final, it would not, by its terms, apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2, 1998) (regulation applies to "loans made on or after the date that is three months after the date of publication o…
  17. PLR 202430007 — Employees of Businesses Under Common Control
    IRCPrivate Letter RulingsJul 26, 2024
    …in section 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub . L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020), as amended by section 206 of the Taxpayer Certainty and Disaster Tax Relief Act (Relief Act), which was e nacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L…
  18. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …ome forward with persuasive evidence that the penalt ies are inappropriate. See § 7491(c); Higbee , 116 T.C. at 446 – 47. Petitioners may meet their burden by proving that they acted with reasonable cause and in good faith with respect to the underpayment s . See § 6664(c)(1); see also Higbee , 116 T.C. at 447; Treas. …
  19. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …deduct its contributions to the Marlton Plan and increased the Los’ income by $102,500 in 1993 and $116,212 in 1994 to reflect the following adjustments: 1993 1994 Contributions to the Marlton Plan $100,000 $120,000 Administrator’s fees 2,500 500 Subtotal 102,500 120,500 Less: P.S. 58 costs included in income -0- 4,288…
  20. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014
    …pect to the liability of any individual for penalties and additions to tax. Higbee v. Commissioner, 116 T.C. 438, 446 (2001); Trowbridge v. Commissioner, T.C. Memo. 2003-164, aff'd, 378 F.3d 432 (5th Cir. 2004). In order to meet the burden of production under section 7491(c), the Commissioner need only make a prima fac…