75 FR 48283 — Liability for Termination of Single-Employer Plans; Treatment of Substantial Cessation of Operations PBGCProposed Rules (FR)Proposed Aug 10, 2010
…part 4062 is revised to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1303(a), 1362-1364, 1367, 1368.
2. Section 4062.1 is revised to read as follows:
§ 4062.1
Purpose and scope.
IRCRegulationsMay 18, 2016
…stock in an S corporation owned by an ESOP include any distributions, within the meaning of section 1368, made on S corporation stock held in a disqualified person's account in the ESOP (including earnings thereon), plus any proceeds from the sale of S corporation securities held for a disqualified person's account in …
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCRegulationsMay 18, 2016
…s attributable to S corporation securities include any distributions, within the meaning of section 1368, made on S corporation stock held in a disqualified person's account in the ESOP (including earnings thereon), plus any proceeds from the sale of S corporation securities held for a disqualified person's account in …
PLR 201125009 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan IRCPrivate Letter RulingsJun 24, 2011
…the date the date of transfer and the date
of transfer of disclaimer
Rev. Rul. 2005-36, 2005-1 C.B. 1368, provides that a beneficiary’s receipt of
RMDs from an IRA constitutes accepta nce of that portion of the corpus of such account,
plus the income attributable to that amount. The beneficiary’s acceptance, however, o…
IRCProposed Rules (FR)Proposed Oct 31, 2023related by meaning
to a state, and (3) must not be released by a state to the public or any third party, unless explicitly approved in writing, in advance, by Treasury. (d) Liability. Treasury is not liable for any loss, liability, cost, or expense that may result from a state's receipt, use, or distribution of records or any information…
86 FR 9120 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCFinal Rules (FR)Feb 11, 2021
…Economic Growth, Regulatory Relief, and Consumer Protection Act, Public Law 115-174, 132 Stat. 1296-1368 (2018), codified at 12 U.S.C. 1831f. 84 FR 1346 (February. 4, 2019). Section 202 amends section 29 of the FDI Act to except a capped amount of reciprocal deposits from treatment as brokered deposits for certain insu…
IRCCourt RulingsJan 26, 2006
…7); Megibow v.
Commissioner
, T.C. Memo. 2004-41; see also Lignos v. United
States
, 439 F.2d 1365, 1368 (2d Cir. 1971).
The IRS employee made a mistake of law by including only
$1,532 as the taxable portion of the $15,322.69 distribution,
instead of the entire distribution of $15,322.69. Equitable
estoppel does not ba…
IRCCourt RulingsJan 2, 2020related by meaning
er. Mrs. Gebman did not provide any evidence that persuades us that
she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file
amendment to petition filed August 28, 2019.
VI. Section 6662(a) Penalties
Section 6662(a) an…
IRCCourt RulingsMar 9, 2011
…ssthrough S corporation
income to petitioners from ADF, and (4) incdme to petitioners
under section 1368 to the extent, if any, the distributions they
were deemed to have received from ADF exceeded their bases in
ADF. Respondent made no such adjustments and, in fact, issued a
no-change letter to ADF. Respondent made no…
IRCCourt RulingsJul 11, 2024
…ner must consider information that
relates to [that] taxpayer , ” Scar v. Commissioner, 814 F.2d at 1368. And
i n Dees, 148 T.C. at 6, we explained that to determine whether a notice
of deficiency is valid , “we look to see whether the notice objectively put
a reasonable taxpayer on notice that the Commissioner determi…
PBGCFinal Rules (FR)Nov 5, 2010related by meaning
1 CFR 285.13.
(b) This section does not apply to loans provided to multi-employer pension plans pursuant to 29 U.S.C. 1431, 29 CFR 4261.1 and 4281.47. (c) A debtor who has a judgment lien against the debtor's property for a debt to the United States is not eligible to receive grants, loans or funds directly or indirect…
IRCCourt RulingsDec 13, 2012
…ld entail ignoring or judicially rewriting the plain language of the Internal Revenue Code." Id. at
1368-1369. The Court of Appeals in Scar found no "determination" had been
made by the Commissioner because "the Commissioner's purported notice of
deficiency revealed on its face that no determination of tax deficiency h…
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
RT 4065—ANNUAL REPORT
26. The authority citation for part 4065 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1365.
§ 4065.3
[Amended] 27. Amend § 4065.3 by removing “(Approved by the Office of Management and Budget under control number 1212-0026)”.
PART 4203—EXTENSION OF SPECIAL WITHDRAWAL LIABILITY RU…
IRCCourt RulingsJun 8, 2005
…7); Megibow v. Commissioner
, T.C. Memo.
2004-41; see also Lignos v. United States
, 439 F.2d 1365, 1368
(2d Cir. 1971).
The doctrine of equitable estoppel was raised for the first
time by respondent on brief.
13
Initially, respondent conceded
that qualified higher education expenses include transportation
costs. In re…
89 FR 4662 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAFinal Rules (FR)Jan 24, 2024related by meaning
t to which the exemption application applies, as well as a reminder that applicants should not submit social security numbers with their applications. Beyond those changes, the Department proposed to revise paragraph (a)(6) to address foreign convictions more clearly, which was further revised in the Final Amendment so…
IRCCourt RulingsDec 5, 2007
…e with the Federal income tax law
applicable to S corporations, most particularly sections 1367 and
1368, our disallowance of the deductions claimed by the PCs has
the effect of increasing pro tanto the net income of those PCs,
with corresponding increases to the doctors' distributive shares
of that income
. That being…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
IRCCourt RulingsFeb 9, 2023
…s Act” modifies the term “statutory provisions.”
Grapevine Imp. , L td. v. United States , 636 F.3d 1368, 1381 n.6 (Fed.
Cir. 2011), vacated and remanded, 566 U.S. 971 (2012); Esden v. Bank
of Bos . , 229 F.3d 154, 171 n.21 (2 d Cir. 2000); TBL Licensing LLC v.
Commissioner , 158 T.C. at ___ ( slip op. at 25 n.10 ) ; I…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…