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73 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. REG-118988-22 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Feb 18, 2025related by meaning
    ration) by email at publichearings@irs.gov (preferred) or by telephone at (202) 317-6901 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Authority These proposed regulations are issued under the express delegation of authority under section 7805 of the Code. Section 7805(a) directs the Secretary of the Treasury or …
  2. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987
    …payment of $5,000 towards their liability. Efforts to collect the remaining balance then ensued. In 1981, one of respondent’s revenue officers became aware of petitioner’s Keogh account at Amerifirst. Thereafter, on April 17, 1981, respondent served a notice of levy on Amerifirst against the account. As of the date the…
  3. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …ALTH PLANS Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
  4. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    acted in good faith with respect to such portion. ” Unlike the reasonable cause and good faith exception found in section 6664(c), Congress placed the adequate disclosure exception in section 6662(d), with no text indicating that it was meant to apply to multiple section 6662 penalties. The reason for t his is apparent…
  5. I.R.C. § 72(r)(2)(B)(ii) — Annuities; certain proceeds of endowment and life insurance contracts
    IRCCode / StatuteJan 6, 2025
    (r)(2)(B)(ii) (ii) After September 30, 1981, and before 1985 With respect to compensation paid before 1985 for services rendered after September 30, 1981, the tier 2 portion shall be— (r)(2)(B)(ii)(I) (I) so much of the tax imposed by section 3201 as is determined at the 2 percent rate, and (r)(2)(B)(ii)(II) (II) so mu…
  6. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
    IRCCourt RulingsJun 4, 1984related by meaning
    ould impose an excise tax sanction for a violation of the prohibited transactions provisions. [H. Rept. 93-1280 (Conf.), 322 (1974), 1974-3 C.B. 483.] The alternative sanctions imposed with respect to improper trust administration either under the labor provisions of ERISA or under section 4975 of the Internal Revenue …
  7. Treas. Reg. § 1.219-2(h) — Definition of active participant.
    IRCRegulationsApr 14, 2016
    … he is a participant in the plan. However, B completes less than 1,000 hours of service in 1980 and 1981. Although B is not accruing any benefits under the plan in 1980 and 1981, he is an active participant under section 219(b)(2) because he is a participant in the plan. Thus, B cannot make deductible contributions to …
  8. Treas. Reg. § 1.410(a)-5(c)(3)(ii) — Year of service; break in service.
    IRCRegulationsSep 9, 2016
    …December 31, 1980, and incurs a 1-year break in service for the 12-month period ending December 31, 1981. The plan does not contain the provisions permitted by section 410(a)(5)(B) (relating to 3-year 100 percent vesting) and section 410(a)(5)(D) (relating to nonvested participants). Thereafter, he does not complete a …
  9. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
  10. T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.…
    IRCTreasury DecisionsApr 30, 2007
    Comprehensive regulations regarding section 415 were last issued in 1981. See T.D. 7748, 1981-1 C.B. 259, published in the Federal Register on January 7, 1981 (46 FR 1687). Since then, changes to section 415 have been made in the Economic Recovery Tax Act of 1981, Public Law 97-34 (95 Stat. 320) (ERTA), the Tax Equity …
  11. PLR 201848011 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 30, 2018
    …contributions. Revenue Ruling 2006-43, 2006-35 I.R.B. 329, amplifying and modifying Rev. Rul. 81-35 1981-5 I.R.B. 11, 1981-1 C.B. 255, Rev. Rul. 81-36 1981-5 I.R.B. 12, 1981-1 C.B. 255, and Rev. Rul. 87-10 1987-5 I.R.B. 4, 1987-1 C.B. 136, des cribes the actions required for a state or political subdivision of a state,…
  12. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  13. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998
    …Shedd served as executive vice president of Estes Co. until his retirement from that company during 1981. To effectuate his retirement, petitioner and WE 7 amended their partnership agreement to provide, in effect, for the buyout of petitioner's interest in Estes Co. Under the terms of the amended partnership agreement…
  14. T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner
    IRCCourt RulingsApr 27, 1998
    on 314(c)(1) of the Economic Recovery Tax Act of 1981 (ERTA), Pub. L. 97-34, 95 Stat. 172, 286, provides that a distributee is taxed on benefits under a qualified retirement plan in the tax year in which those benefits are "actually distributed". Prior to the 1981 amendment, section 402(a)(1) provided that amounts held…
  15. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    … the computation to start on the same date the COLA's were started under the EAJA; i.e., October 1, 1981. Id. at 23. Citing Lawrence v. Commissioner , 27 T.C. 713 (1957), revd. on other grounds 258 F.2d 562 (9th Cir. 1958), we stated that we would continue to use 1981 as the correct year for making the COLA calculation…
  16. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000
    …s were liable for a $3,099 addition to tax under section 6659 as a result of this underpayment. The 1981 notice reflects respondent’s determination that the portion of the disallowed investment tax credit that petitioners carried back to 1981 results in an underpayment in tax of $1,926 for 1981. The 1981 notice determi…
  17. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    …ed States, 417 F.2d 675, 679 (5th Cir. 1969); Arrow Fastener Co. v. Commissioner, 76 T.C. 423, 430 (1981). We must invalidate a regulation if the Secretary has “usurp[ed] the authority of Congress by adding restrictions to a statute which are not there.” Estate of Boeshore v. Commissioner, 78 T.C. 523, 527 (1982). Howe…
  18. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
    IRCTreasury DecisionsSep 18, 2006related by meaning
    nder section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. ADMINISTRATIVE Rev. Proc. 2006-34 Rev. Proc. 2006-34 This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure …
  19. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985
    …sions of section 7456(d) of the Code. Respondent determined a deficiency of $474.10 in petitioner’s 1981 Federal income tax. The issue for decision is whether petitioner is entitled to a deduction of $1,500 for a contribution to an Individual Retirement Account (IRA). At the time of filing his petition, petitioner resi…
  20. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987
    …rences to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts with effective dates during 1980 and 1981; Act of October 10, 1980, Pub. L. 96-417, tit. V, sec. 501(9), 94 Stat. 1727, 1742 (effective Nov. 1, 1980), and Act…