29 C.F.R. § 2550.408e(a) — Statutory exemption for acquisition or sale of qualifying employer securities and for acquisition, sale, or lease of qualifying employer real property. ERISARegulationsJan 1, 2017
… the Act any acquisition or sale by a plan of qualifying employer securities (as defined in section 407(d)(5) of the Act), or any acquisition, sale or lease by a plan of qualifying employer real property (as defined in section 407(d)(4) of the Act) if certain conditions are met. The conditions are that:
(a)(1) (1) The …
IRCCourt RulingsJun 12, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
T.C. Memo. 1996-272
UNITED STATES TAX COURT
TOMMY L. AND PATRICIA A. HOBSON, Petitioners v
. COMMISSIONER OF
INTERNAL R…
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAFinal Rules (FR)Jan 24, 2024
…ecifically applies to such conduct. To supplement these provisions, ERISA sections 406(a)(1)(E) and 407(a) impose restrictions on the nature and extent of plan investments in assets such as “employer securities” (as defined in ERISA section 407(d)(1)) and “employer real property” (as defined in ERISA section 407(d)(2))…
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022
…ecifically applies to such conduct. To supplement these provisions, ERISA sections 406(a)(1)(E) and 407(a) impose restrictions on the nature and extent of plan investments in assets such as “employer securities” (as defined in ERISA section 407(d)(1)) and “employer real property” (as defined in ERISA section 407(d)(2))…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
rom the proceeds of the life insurance contract. See generally Cadwell
v. Commissioner, 136 T.C. 38, 63-64 (2011), aff'd, 483 Fed. Appx. 847 (4th Cir. 2012). Section 1.61-22, Income Tax Regs., is effective for split-dollar life
insurance arrangements entered into after September 17, 2003, and an arrangement
that is "ma…
85 FR 72846 — Financial Factors in Selecting Plan Investments ERISAFinal Rules (FR)Nov 13, 2020
…entical investments as a “unicorn”).
Back to Citation
104. The Department estimated that there are 407,383 DC plans with QDIAs and that 0.1 percent, or 407 plans, will need to reconsider their QDIAs as a result of the rule. The burden is estimated as follows: (407,383 plans * 0.001 * 20 hours) = 814 hours. A labor rat…
T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a … IRCTreasury DecisionsMay 7, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-29 Rev. Rul. 2007-29
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007.
Announcement 2007-44 Announcement 2007-44
This anno…
IRCCourt RulingsJun 14, 2012related by meaning
o. 17204-09
Additions to tax and penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)' Sec. 6662A
2004 $28,779 $1,179.23 to be determined $9,259.32 2005 83,908 2,131.20 to be determined . 21,855.65
2006 62,339 3,645.68 to be determined 13,879.43
1Respondent explains in the notice of deficiency that the additions to …
IRCCourt RulingsMay 12, 1971related by meaning
g $1,000,
may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
Atkins, Judge:
The respondent allowed claims for net renegotiation rebates for the calendar years 1942, 1943, and 1944 in the respective amounts of $2,163.21, $87,717.10, and $167,421.69. The petitioner alleges that the respondent erred in failing to allow net renegotiation rebates for those years in the respective amo…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
IRCCourt RulingsMar 31, 1997related by meaning
ons of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
- 3 - After concessions, the following 2 issues remain for us to
resolve in the present proceeding: (1) Whether petitioner, in
its taxable year ending January 30, 1988 (TYE 88…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
IRCCourt RulingsJan 30, 2007related by meaning
s were attributable to
disability, or that the distributions otherwise qualify for an
exception to the 10-percent additional tax. In fact, petitioners state on brief that "Petitioners do understand that petitioners
have to pay 10% penalty tax on the amount stated above * * * This
is consistent with IRC section 72(t) (1…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJun 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…