ERISARegulationsJan 1, 2017related by meaning
[Reserved]
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.…
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…
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 …
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 …
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…
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…
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…
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…
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
…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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
…