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72 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …g. Back to Citation 759.  This is estimated as: 358 firms × 4 hours ≉ 1,430 hours. A labor rate of $133.24 is used for a Senior Executive Officer. The labor rate is applied in the following calculation: 1,430 hours × $133.24 ≉ $190,594. Back to Citation 760.  This is estimated as: 259,230 retrospective reviews × (5 min…
  2. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
  3. Treas. Reg. § 1.401(l)-3(c)(2)(vi)(B) — Permitted disparity for defined benefit plans.
    IRCRegulationsMay 18, 2016
    …substituted for the nondisparate percentage. For this purpose, the 411(b)(1)(B) limit percentage is 133 1/3 percent of the smallest base benefit percentage, or 133 1/3 percent of the smallest difference between the gross benefit percentage and the offset percentage, whichever is applicable, where the smallest base bene…
  4. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996related by meaning
    for which respondent was not substantially justified, and the Algonquin property issue, for which respondent was substantially justified. Based on the record, we find that for the period December 1992 until September 1993, 29 a total of 312.9 hours was spent by counsel in connection with the Court proceedings. Of this …
  5. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994related by meaning
    years in issue in respect of a reserve for postretiremerit medical and life insurance benefits within the meaning of section 419A(c)(2). C. Conclusion Based on the foregoing, we hold that petitioner’s account limit under section 419A(c)(l) attributable to claims incurred but unpaid for medical benefits is $3,876,709 an…
  6. 84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Oct 23, 2019
    …ours to develop and review the Initial Notice. Assuming the hourly rate for in-house attorneys was $133.50 in 2016, the costs of developing the Initial Notice are estimated approximately $39 million (292,725 hours * $133.50). Back to Citation 101.
  7. Treas. Reg. § 54.9815-2713A(a) — Accommodations in connection with coverage of preventive health services.
    IRCRegulationsJan 14, 2019
    …The organization is an objecting entity described in 45 CFR 147.132(a)(1)(i) or (ii), or 45 CFR 147.133(a)(1)(i) or (ii); (a)(2) (2) Notwithstanding its status under paragraph (a)(1) of this section and under 45 CFR 147.132(a) or 147.133(a), the organization voluntarily seeks to be considered an eligible organization t…
  8. T.C. Memo. 2005-133 — Gloria Yuen-Mee Ho & Alexander Chi-Shun Tsang v. Commissioner
    IRCCourt RulingsJun 2, 2005
    T.C. Memo. 2005-133 UNITED STATES TAX COURT GLORIA YUEN-MEE HO AND ALEXANDER CHI-SHUN TSANG, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3242-04, 18499-04. Filed June 2, 2005. Gloria Yuen-Mee Ho and Alexander Chi-Shun Tsang, pro sese. T. Richard Sealy III and Kelli H. Todd , for respondent.…
  9. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    133 T .C . No . 9 UNITED STATES TAX COUR T TAPROOT ADMINISTRATIVE SERVICES, INC ., Petitioner _v . COMMISSIONER-OF INTERNAL REVENUE, Responden t Docket No . 15396-07 . . Filed . September 29,,2009 . R determined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retireme…
  10. 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…
  11. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    w that there is a genuine dispute for trial that he had reasonable cause for not paying the unpaid tax on the 2013 return made for him by RA Landadio. C. Summary Judgment Rule 121(b) provides that, in the absence of a genuine dispute as to any material fact, and if a decision may be rendered as a matter of law, we must…
  12. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    IRCCourt RulingsMay 23, 2005related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2001, the taxable year in issue. All monetary amounts are rounded to the nearest dollar. T.C. Summary Opinion 2005-62 UNITED STATES TAX COURT THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v . COMMISS…
  13. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …a “is a measure of the tendency of a security’s price to respond to swings in the market.” Veritas, 133 T.C. at 319. The market typically is estimated by reference to a n index like the S&P 500 . T he beta of the S&P 500 —the correlation of the market with itself —is one. If a company has a beta greater than one, its r…
  14. T.C. Summary Opinion 2002-133 — Thomas H. Ploss v. Commissioner
    IRCCourt RulingsOct 10, 2002
    T.C. Summary Opinion 2002-133 UNITED STATES TAX COURT THOMAS H. PLOSS, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1217-01S. Filed October 10, 2002. Thomas H. Ploss, pro se. David S. Weiner , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of sectio…
  15. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ing plan. Held, such transfer is an employer reversion subject to the 10-percent excise tax under sec. 4980, I.R.C. Robert L. Raymond, for petitioner. P. Joseph Ineich, for respondent. *54 Hamblen, Chief Judge. HAMBLEN *189 OPINION Hamblen, Chief Judge: This case was assigned to Special Trial Judge Francis J. Cantrel p…
  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. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    …ber documents, Mr. Arneson testified that he first mailed the documents to Ms. Hatchett at BB&L. (T 133) He verified again that he was authorized to mail the check for $15,000.00 on December 31, 1998. (T 133) The authorization he received to do so was the settlement agreement itself. (T 134) He also specifically identi…
  18. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …tement. See Corson v. Commissioner, T.C. Memo. 2009-95, slip op. at 16. Petitioners must not only - 133 - [*133] prove the existence of an unreasonable error or delay in performing a managerial or ministerial act, see Rule 142(a); they must also connect the error or delay with the "specific period for which interest sh…
  19. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
  20. 89 FR 58886 — Required Minimum Distributions
    IRCFinal Rules (FR)Jul 19, 2024
    …g distributions from Plan W in the form of a straight life annuity paid with annual payments of $92,133 per year. (B) Analysis. Because payment of retirement benefits in the form of a straight life annuity satisfies (in terms of form) section 401(a)(9), the condition under paragraph (n)(3)(i) of this section is met. Be…