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41. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
42. 29 C.F.R. § 4000.28 — [Reserved]
    PBGCRegulationsDec 7, 2023related by meaning
    [Reserved]
43. 29 C.F.R. § 4902.9(i) — Privacy Act provisions for which PBGC claims an exemption.
    PBGCRegulationsJan 1, 2017related by meaning
    (i) (i) Subsection (e)(8) of 5 U.S.C. 552a requires an agency to make reasonable efforts to serve notice on an individual when any record on such individual is made available to any person under compulsory legal process when such process becomes a matter of public record.
44. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    … percent. See sec. 4975(a) after amendment by the Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1074, 111 Stat. 949 (first-tier tax rate increased from 10 percent to 15 percent). The second-tier excise tax, equal to 100 percent of the “amount involved”, is imposed when a transaction to which the first-tier tax appl…
45. 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)(…
46. 61 T.C. 605; 61 T.C. No. 65 — Estate of Silverman v. Commissioner
    IRCCourt RulingsFeb 4, 1974
    S. Rept. No. 1983, 85th Cong., 2d Sess. (1958), 1958-3 C.B. 1074. In our view this statement of the Senate Finance Committee is in effect an interpretation of the provisions of section 2039 (c) to mean that only payments received under a qualified plan are to be excluded. In our view if a contract containing no restric…
47. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    icipation. Id. Thus, even though the withdrawal from the taxpayer’s Keogh account was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively receive the funds under section 72(m)(4)(A). 4 In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
48. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
49. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    e, to the extent possible, uncertainty as to timely commencement and as to the beginning of the critical period for timely completion of a proceeding. We have previously considered a like issue involving the necessity of mailing a notice of deficiency by registered mail in order to determine whether a petition therefro…
50. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985
    …e.g., Reuther v. Trustees of Trucking Employees of Passaic and Bergen County Welfare Fund, 575 F.2d 1074 (3d Cir. 1978); Martin v. Bankers Trust Co., 565 F.2d 1276 (4th Cir. 1977); Morgan v. Laborers Pension Trust Fund for Northern California, 433 F. Supp. 518 (N.D. Cal. 1977). Applying section 4975 to the loans in the…
51. 58 T.C. 241 — Estate of Kleemeier v. Commissioner
    IRCCourt RulingsMay 8, 1972
    …r December 31,1957. [Emphasis supplied. S. Rept. No. 1983, 85th Cong., 2d Sess. (1958), 1958-3 C.B. 1074.] The report of the Senate Finance Committee with respect to the addition of paragraph (3) to section 2039(c) continually refers to “payments or contributions made by the decedent,” or “the decedent’s total payments…
52. 29 C.F.R. § 2520.102-1 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
53. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995
    …ments of due process as defined by federal law.” Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 1074 (3d Cir. 1990). In short, it is not enough for petitioner to express a “mere belief that * * * [the first decision] was wrongly decided to avoid the application of the collateral estoppel doctrine.” Disabled America…
54. 29 C.F.R. § 2570.168 — Decision of the administrative law judge.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
55. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
56. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
57. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    PBGCRegulationsJan 1, 2017
    …t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
58. T.C. Summary Opinion 2015-37 — Charles D. Trainito v. Commissioner
    IRCCourt RulingsJun 23, 2015related by meaning
    d $3,186 of debt that petitioner owed. Petitioner did not report - 5 - receiving any income from the cancellation of debt. Petitioner does not dispute that the debt was discharged but rather argues that the section 108(a)(1)(B) exclusion applies. Discussion I. Burden of Proof In general, the Commiissioner's determinati…
59. 29 C.F.R. § 4000.41 — What are these computation-of-time rules about?
    PBGCRegulationsJan 22, 2018
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
60. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    … a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information. 3  Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here: https://www.bls.gov/​news.release/​pdf/​jolts.pd…