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89 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  2. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …00.00 Technical Architect/Sr. Developer 3,120 149.00 464,880.00 Application Developer, Senior 4,160 143.00 594,880.00 Business Analyst 2,080 120.00 249,600.00 UX Researcher/Service Designer 2,080 154.00 320,320.00 Designer 1,560 116.00 180,960.00 DevOps Engineer 2,080 181.00 376,480.00 Web Database/Application Develope…
  3. Rev. Rul. 2022-24 — Section 401.—Qualified Pension, Profit-Sharing, and Stock Bonus Plans
    IRCRevenue RulingsDec 19, 2022
    …1970 2037 133,584 1971 2038 135,684 1972 2039 137,748 1973 2040 139,752 1974 2041 141,636 1975 2042 143,424 1976 2043 145,092 1977 2044 146,616 1978 2045 148,140 1979 2046 149,664 1980 2047 151,104 1981 2048 152,424 1982 2049 153,660 1983 2050 154,860 1984 2051 156,048 1985 2052 156,984 1986 2053 157,896 1987 2054 158,…
  4. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
  5. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    lusion, we need not decide respondent's contention regarding the fact that petitioner did not receive a determination from the United States competent authority as to whether the French retirement plan generally corresponds to a United States retirement plan or that certain documents, including Exhibits 9-P and 12-P, a…
  6. IRCRegulationsSep 9, 2016
    … × 1.025 (actual contribution rate times acutal base units times interest adjustment from mid-year) 143,500 5. Unfunded liability as of 12/31/76: item 1 + item 2 + item 3 −item 4 907,393 (B) Computation of the Outstanding Balance of the Bases as of December 31, 1976 1. Original base: ($900,850−$50,000) × 1.05 $893,393 …
  7. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
  8. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …uire 10 minutes of work per inquiry from an Attorney III (totaling 300 minutes for 30 inquiries at $143 per hour), 20 minutes per inquiry from a Senior Application Developer (totaling 600 minutes for 30 inquiries at $143 per hour), and 30 minutes per inquiry from a Project Manager/Team Lead (totaling 900 minutes for 30…
  9. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996related by meaning
    rst articulated. 3 As a consequence, we set forth that analysis in order to bring into focus the precise question that we must decide, namely, whether the amounts of the accrued vacation and severance pay were "paid" when the letter of credit was purchased on March 13, 1992. Statutory Framework The parties have stipula…
  10. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    January 15, 2020. § 726.302(c)(2)(i) table $143 $146. § 726.302(c)(2)(i) table 285 290. § 726.302(c)(2)(i) table 428 436. § 726.302(c)(2)(i) table 569 579. § 726.302(c)(4) January 23, 2019 January 15, 2020. § 726.302(c)(4) $143 $146. § 726.302(c)(5) January 23, 2019 January 15, 2020. § 726.302(c)(5) $428 $436. § 726.30…
  11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …t of $22,916. At the time of conversion, the Cgroup term policy’s conversion credit balance was $13,143.16, and $12,486 of that amount ($13,143.16 x 95%) was transferred to the C-group conversion UL policy for potential earning. Dr. Desai will earn this amount in 120 equal monthly installments, beginning October 1996. …
  12. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  13. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  14. 143 T.C. No. 5 — Parimal H. Shankar & Malti S. Trivedi v. Commissioner
    IRCCourt RulingsAug 26, 2014
    SA- t4dPd erns) 143 T.C. No. 5 UNITED STATES TAX COURT PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24414-12. Filed August 26, 2014. R disallowed Ps' deduction for contributions to their IRAs, which Ps claim are deductible because the limitations on ded…
  15. T.C. Summary Opinion 2011-16 — Paulette A. & Matthew D. Malena v. Commissioner
    IRCCourt RulingsFeb 24, 2011
    …as let go from his job, and he defaulted on the loan, at which time the outstanding balance was $29,143. Petitioner and her husband filed a joint Federal income tax return for 2007. On the return, petitioner did not report the defaulted loan of $29,143 from her husband's 401(k). Petitioner attached to her joint return …
  16. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    that in Community Services. Because that case was not decided under section 401(a)(7), its holding has no bearing on our decision of the instant case. Since the trustees are also shareholders, directors, and employees participating in the plan, petitioner contends that the State law principles of fiduciary duty prevent…
  17. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  18. 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
    …ion); 2,300 (Internal Revenue Service). Estimated Total Annual Cost Burden (three year average): $1,143,000 (Employee Benefits Security Administration); $1,143,000 (Internal Revenue Service). B. Department of Health and Human Services
  19. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    cation benefits despite the fact the plans did not permit employees to take leave before the service requirements were fully met, and no benefits were actually granted until 3 months after the close of petitioner's taxable year. For each of the plans, although respondent did not acquiesce in petitioner's excessively br…
  20. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014
    T.C. Memo. 2014-143 UNITED STATES TAX COURT KEITH ROBERTSON, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20848-12. Filed July 21, 2014. Keith Robertson, pro se. Bradley C. Plovan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: The Internal Revenue Service (IRS or respon…