IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsFeb 22, 2010related by meaning
Print 1982) .
Sec . 7702 was enacted in 1984 as part of the Deficit Reduction
.
Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments
. postdate the promulgation of the
applicable regulations in 1956, for the reasons . discussed supra
we believe that the cross-reference to se…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
… the assets reported on its four quarterly financial statements for the preceding year.” See 13 CFR 121.201 (as amended by 84 FR 34261, effective August 19, 2019). In its determination, the “SBA counts the receipts, employees, or other measure of size of the concern whose size is at issue and all of its domestic and fo…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
84 FR 24296 — Changes to Applicability Thresholds for Regulatory Capital Requirements for Certain U.S. Subsidiaries of Foreign Banking Organizations and Application of Liqui… IRCProposed Rules (FR)Proposed May 24, 2019
…l entity.
Back to Citation
146.
See 5 U.S.C. 603, 604, and 605. Back to Citation
147.
See 13 CFR 121.201.
Back to Citation
148.
12 CFR part 217.
Back to Citation
149.
12 CFR part 249.
Back to Citation
150.
5 U.S.C. 601
et seq.
Back to Citation
151.
The SBA defines a small banking organization as having $550 mill…
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…
IRCCourt RulingsNov 28, 2023
…ion from a qualified retirement plan. Respondent has filed a
Motion for Summary Judgment under Rule 121, contending that there
are no disputes of material fact and that he is entitled to judgment as a
matter of law. We agree and accordingly will grant the Motion.
Background
The following facts are based on the parties …
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…ternative Investments
(2013) (available at www.oig.dol.gov/public/reports/oa/2013/09-13-001-12-121.pdf);
U.S. Gov't Accountability Office, GAO-12-665, Private Sector Pensions: Federal Agencies Should Collect Data and Coordinate Oversight of Multiple-employer Plans
(2012) (available at
www.gao.gov/assets/650/648…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
76 FR 67105 — Cash Balance Plans; Benefit Determinations and Plan Valuations for Statutory Hybrid Plans; Pension Protection Act of 2006 PBGCProposed Rules (FR)Proposed Oct 31, 2011
… part.
(3)
Involuntary termination exception.
If a benefit payment is calculated pursuant to § 4022.121(a)(3)(ii), the benefit will be valued based on the interest crediting rate and the annuity conversion rate in effect under the plan as of the plan's termination date (subject to the rules of §§ 4022.121 through 4022.…
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 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 …
IRCCourt RulingsSep 17, 2026
…trials. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C . 73, 74 (2001). Ordinarily, under
Rule 121(a)(2) the Court may grant summary judgment when there is
no genuine dispute as to any material fact and the movant is entitled to
judgment as a matter of law . Sundstrand Corp. v. Commissioner, 98
T.C. 518, 520 (1992…
IRCCourt RulingsOct 12, 1978related by meaning
levant documents comprising the application for determination. Such information was furnished to the Department of Labor by the IRS on April 20, 1977. On May 25, 1977, the Commissioner notified the trustees of Central that its plan, as amended effective January 30, 1976, was qualified, provided it adopted the additiona…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
ioners filed their memorandum on February 12, 2014, and
(continued...)
- 63 -
As an exception to the general rule of section 1.61-22(b)(1), Income Tax Regs., an arrangement between an owner and a nonowner of a life insurance
contract is a split-dollar life insurance arrangement if it is either a compensatory
arrangemen…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 601(3) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
100.
Medical Expenditure Panel Survey Insurance Component, Agency for Healthcare Researc…
IRCProposed Rules (FR)Proposed May 13, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
186.
13 CFR 121.201 (2011).
Back to Citation
187.
15 U.S.C. 631
et seq.
(2011).
Back to…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
43.
13 CFR 121.201 (2011).
Back to Citation
44.
15 U.S.C. 631
et seq.
(2011).
Back to C…
IRCCourt RulingsJan 3, 2017related by meaning
* * [she] normally would have been allowed." In
later correspondence she sent to respondent in 2013, petitioner continued to plead
financial hardship. On December 9, 2013, respondent mailed petitioner a notice of deficiency,
determining that the section 72(t) additional tax was applicable to the entire
amount of the di…