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41. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …y preliminary development steps were taken and no sales activities occurred) , aff’d , 770 F. App’x 1016 (11th Cir. 2019) . Petitioner suggest s that respondent advances a “novel” statutory interpretation. The argument is unpersuasive. The inquiry under section 163(d) into whether property is held for investment substa…
42. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…
43. 89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAFinal Rules (FR)Jan 24, 2024related by meaning
    nt must promptly notify the Department in writing if it learns that a material fact or representation has been omitted from the exemption application. (b) If, at any time during the pendency of an exemption application, the applicant or any other party in interest who would participate in the exemption transaction beco…
44. Treas. Reg. § 1.101-1(f)(4)(iii)(A) — Exclusion from gross income of proceeds of life insurance contracts payable by reason of death.
    IRCRegulationsJul 9, 2026
    …ibed in paragraph (f)(4)(iii)(A) of this section, the adjusted bases (within the meaning of section 1016) of such assets. (f)(5) (5) Transfer for valuable consideration. A transfer for valuable consideration means any transfer of an interest in a life insurance contract for cash or other consideration reducible to a mo…
45. Treas. Reg. § 1.410(a)-2(d) — Effective dates.
    IRCRegulationsSep 9, 2016
    … The provisions referred to are the amendments to the Code made by sections 1011, 1012, 1013, 1015, 1016(a) (1) through (11) and (13) through (27), 1021, and 1022(b) of the Employee Retirement Income Security Act of 1974. (d)(2) (2) Election is irrevocable. Any election made under this paragraph, once made shall be irr…
46. 29 C.F.R. § 2570.161 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
47. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …ty Cohort, Journal of Urology, Vol. 191, No. 2 (Feb. 1, 2014), https://www.auajournals.org/​doi/​10.1016/​j.juro.2013.08.083. Back to Citation 134.  Alina Salganicoff, Brittni Frederiksen, and Usha Ranji, Will Trump's Announcement Expand Access to IVF?, KFF (Oct. 27, 2025), https://www.kff.org/​womens-health-policy/​wi…
48. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …ence from Secondary Market Transactions, 132 J. Fin. Econ. 158, 158-181 (2019), https://doi.org/​10.1016/​j.jfineco.2018.11.007. Back to Citation 71.  This analysis was conducted using the Public Plans Database (PPD), which consists of roughly 220 major public pension plans (118 state and 100 local) that represent over…
49. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
50. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984
    …etroleum Co., 583 F. Supp. 1113 (D. Kan. 1984); Wishner v. St. Luke’s Hospital Center, 550 F. Supp. 1016 (S.D.N.Y. 1982); Beck v. Shaw Industries, Inc., No. C81-72A (N.D. Ga., Dec. 29, 1981).
51. PLR 201129029 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJul 22, 2011
    …hall be the basis (determined under § 1012 or other applicable sections), adjusted as provided in § 1016. Accordingly, the Fee paid to Issuer will be taken into account in the determination of a Customer’s “investment in the contract” for the Contract under § 72 and the Customer’s adjusted basis in the Contract under §…
52. 29 C.F.R. § 2570.7 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
53. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990
    … however, amended the Code so that sec. 6501(e)(3) now applies to those taxes. Pub. L. 93-406, sec. 1016(a)(14), 88 Stat. 930.
54. PLR 201128017 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsJul 15, 2011
    …hall be the basis (determined under § 1012 or other applicable sections), adjusted as provided in § 1016. Accordingly, the Fee paid to the Taxpayer will be taken into account in the determination of the Customer’s “investment in the contract” for the Contract under § 72 and the Customer’s adjusted basis in the Contract…
55. PLR 201105005 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsFeb 4, 2011
    …all be the basis (determined under § 1012 or other applicable sec tions), adjusted as provided in § 1016. Accordingly, The Periodic Fee paid to Taxpayer will be taken into account in the determination of an Account Owner’s “investment in the contract” for the Certificate
56. 29 C.F.R. § 2570.61 — Definitions.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
57. PLR 201105004 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsFeb 4, 2011
    …hall be the basis (determined under § 1012 or other applicable sections), adjusted as provided in § 1016. Accordingly, The Periodic Fee paid to Taxpayer will be taken into account in the determination of an Account Owner’s “investment in the contract” for the Certificate under § 72 and the Account Owner’s adjusted basi…
58. Court of Appeals for the Ninth Circuit — Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.
    ERISACourt RulingsAug 31, 2026
    …sal under Federal Rule of Civil Procedure 12(b)(6). Moore v. Mars Petcare US, Inc. , 966 F.3d 1007, 1016 (9th Cir. 2020). In evaluating a motion to dismiss, “[a]ll allegations of material fact in the complaint are taken as true and construed in the light most favorable to Plaintiffs.” Id . To withstand a motion to dism…
59. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
60. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …evidence will suffice for each member to make a prima facie showing on the question, or the issue is susceptible to generalized, class-wide proof” and (2) “determination of the question’s truth or falsity will