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93 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  2. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
  3. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    … the expert’s qualification s and the evidence in the record. Se e Helvering v. Nat’l Grocery Co. , 304 U.S. 282, 295 (1938); Estate of Mellinger v. Commissioner, 112 T.C. 26, 39 (1999). The persuasiveness of an expert’s opinion depends largely on the facts and assumptions on which it is based . Estate of Davis v. Comm…
  4. 29 C.F.R. § 2520.101-5(b)(3)(ii)(A) — Annual funding notice for defined benefit pension plans.
    ERISARegulationsSep 9, 2020
    …) (A) A statement of the value of the plan's assets (determined in the same manner as under section 304(c)(2) of the Act) and liabilities (determined in the same manner as under section 305(i)(8) of the Act, using reasonable actuarial assumptions as required under section 304(c)(3) of the Act) as of the valuation date …
  5. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    at 568 – 69. Petitioner has not explained why the result should be different here. Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . . made by reason …
  6. 88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCFinal Rules (FR)Feb 23, 2023related by meaning
    7805 * * * * * * * * Section 1.6033-4 also issued under 26 U.S.C. 6033. * * * * * Section 1.6037-2 also issued under 26 U.S.C. 6037. * * * * * Par. 2. Section 1.1461-1 is amended by removing paragraph (c)(5); redesignating paragraph (i) as paragraph (j); adding a new paragraph (i); and revising newly redesignated parag…
  7. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  8. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996related by meaning
    sidered separately. This bifurcated analysis: not only ensures that the prevailing taxpayer is reimbursed for pre-litigation and litigation costs, but also supports Congress's intent that before an award of attorney's fees is made, the taxpayer must meet the burden of proving that the Government's position was not subs…
  9. 34 T.C. 851 — West Virginia Steel Corp. v. Commissioner
    IRCCourt RulingsAug 15, 1960related by meaning
    n this report. All statutory references herein are to the Internal Revenue Code of 1939, unless otherwise specified. SEC. 291. FAILURE TO PILE RETÜRN. (a) In ease of any failure to make and file return required by this chapter, -within the time prescribed by law or prescribed by the Commissioner in pursuance of law, un…
  10. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ired the compilation of pre - September 24, 1935 documents. Act of June 19, 1937, ch. 369, 50 Stat. 304. The reason for the amendment was the realization that “mere compilations of documents were almost unusable because of their bulk and la ck of uniformity.” Titles 1-6 C.F.R. v (1939). The 1937 amendment replaced the …
  11. PLR 201111018 — Minimum Funding Standards
    IRCPrivate Letter RulingsMar 18, 2011
    …cribed in sections 431 (b)(2)(8) and 431 (b)(4) of the Internal Revenue Code ("Code"), and sections 304(b)(2)(8) and 304(b)(4) of the Employee Retirement Income Security Act of 1974 ("ERISA"). This extension is effective with the plan year beginning January 1,2009. This extension applies to the eligible amortization ch…
  12. PLR 201103059 — Minimum Funding Standards
    IRCPrivate Letter RulingsJan 21, 2011
    …escribed in sections 431 (b)(2)(B) and 431 (b)(4) ofthe Intemal Revenue Code ("Code"), and sections 304(b)(2)(B) and 304(b)(4) ofthe Employee Retirement Income Security Act of 1974 ("ERISA"). This extension is effective with the plan year beginning May 1, 2010. This extension applies to the eligible amortization charge…
  13. 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…
  14. PLR 202439016 — Minimum Funding Standards for Multiemployer Plans
    IRCPrivate Letter RulingsSep 27, 2024
    …escribed in sections 431(b)(2){B) and 431(b)(4) of the Internal Revenue Code ("Code"}, and sections 304(b)(2)(8) and 304(b)(4) of the Employee Retirement Income Security Act of 197 4 ("ERISA"). This extension is effective with the plan year beginning January 1, 2023 and applies to the eligible amortization charge bases…
  15. 78 FR 20039 — Reportable Events and Certain Other Notification Requirements
    PBGCProposed Rules (FR)Proposed Apr 3, 2013related by meaning
    e on the applicability and enforcement of ERISA section 4062(e). PBGC is currently giving careful consideration to the comments on that proposed rule. Back to Citation 32.  Such “non-statutory” contributions are not taken into account under ERISA section 303(k) and Code section 430(k), dealing with liens that arise bec…
  16. PLR 202439017 — Minimum Funding Standards for Multiemployer Plans
    IRCPrivate Letter RulingsSep 27, 2024
    …cribed in sections 431 (b)(2)(8) and 431 (b)(4) of the Internal Revenue Code ("Code"), and sections 304(b)(2)(8) and 304(b)(4) of the Employee Retirement Income Security Act of 197 4 ("ERISA"). This extension is effective with the plan year beginning January 1, 2023 and applies to the eligible amortization charge bases…
  17. PLR 201616012 — Minimum Funding Standards for Multiemployer Plans
    IRCPrivate Letter RulingsApr 15, 2016
    …cribed in sections 431 (b)(2)(B) and 431 (b)(4) of the Internal Revenue Code ("Code"), and sections 304(b)(2)(8) and 304(b)(4) of the Employee Retirement Income Security Act of 1974 ("ERISA"). This extension is effective with the plan year beginning May 1, 2014. This extension applies to the eligible amortization charg…
  18. PLR 201526024 — Minimum Funding Standards for Multiemployer Plans
    IRCPrivate Letter RulingsJun 26, 2015
    …escribed in sections 431(b)(2)(B) and 431(b)(4) of the Internal Revenue Code ("Code"), and sections 304(b)(2)(B) and 304(b)(4) of the Employee Retirement Income Security Act of 1974 ("ERISA"). This extension is effective with the plan year beginning· . This extension applies to the eligible amortization charge bases, e…
  19. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    ion 6662(a) and (b) (2). Generally, section 6662(a) and (b) (1) authorizes the Commissioner to impose a 20-percent penalty on the portion of an - 72 - underpayment of income tax attributable to negligence or disregard of rules or regulations. The term "negligence" includes any failure to make.a reasonable attempt to co…
  20. PLR 201526025 — Minimum Funding Standards for Multiemployer Plans
    IRCPrivate Letter RulingsJun 26, 2015
    …escribed in sections 431(b)(2)(B) and 431(b)(4) of the Internal Revenue Code ("Code"), and sections 304(b)(2)(B) and 304(b)(4) of the Employee Retirement Income Security Act of 1974 ("ERISA"). This extension is effective with the plan year beginning . This extension applies to the eligible amortization charge bases as …