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79 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  2. 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 …
  3. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    …xpected to be $6,760 ($5,960 + $800), or $563.33 per month, and the associated death benefit is $56,333. The expected increase in the amount of the death benefit attributable to the increase in Participant A's accrued benefit is therefore $6,666 ($56,333 − $49,667).(vii) Participant A's projected accrued benefit at nor…
  4. 29 C.F.R. § 2560.502c-6(i)(3)(ii) — Civil penalties under section 502(c)(6).
    ERISARegulationsJan 1, 2017related by meaning
    (i)(3)(ii) (ii) Upon receipt by the delivery service, if accomplished using a “designated private delivery service” within the meaning of 26 U.S.C. 7502(f); (i)(3)(iii) (iii) Upon transmittal, if transmitted in a manner specified in the notice of intent to assess a penalty as a method of transmittal to be accorded such…
  5. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …f the amount contributed over the amount allowable as a contribution. B. Notice 2004-8, 2004-1 C.B. 333 On December 31, 2003, the IRS issued Notice 2004-8, 2004-1 C.B. 333, titled Abusive Roth IRA Transactions. In that notice the IRS addressed taxpayers' attempts to avoid limitations on contributions to Roth IRAs. It s…
  6. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011
    …r those years DISC commissions of $465,392, $334,315, and $297,052 and taxable income of $463,557, $333,119,.and $294,657, 'respectively. ADF deducted the payment of these DISC commissions to ADF International·. (2) As a result of its status as a-DISC, ADF International was deemed to have made distributions of . DISC i…
  7. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008related by meaning
    ven such regulations is well known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v. Commissioner, 515 F.3d 162 (3d Cir. 2008), vacating 126 T.C. 96 (2006). The delegation Congress made to the Secretary in section 404(k)(5) (A), however, is particularly …
  8. 81 FR 47534 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    … GIA. Consecutively number others as 502, 503 . . . Exception. If Part II, Line 9a is completed and 333 (or a higher number in a sequence beginning with 333) was previously assigned to the plan, that number may be entered on Line 1b. Line 1c. Enter the date the plan first became effective. Line 2a. Limit your response …
  9. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …on that petitioners claimed is miscalculated. We find that the proper amortization deduction is $21,333 (petitioner husband's cost basis of $320,000, divided by 15). Accordingly, petitioners are entitled to an amortization deduction of $21,333 for 2013.¹³ ¹² Sec. 197 intangibles do not include an interest in a partners…
  10. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007
    …e of a new home, and being both a single father and temporarily unemployed, petitioner withdrew $86,333 .33 from his IRA .3 Petitioner used the proceeds, net of withheld taxes, to help finance the downpayment for his new home . Petitioner was 46 years old and not disabled in 2003 when he received the IRA distribution .…
  11. 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…
  12. T.C. Memo. 2007-333 — Jeanne E. Amarasinghe v. Commissioner
    IRCCourt RulingsNov 6, 2007
    T .C . Memo . 2007-333 UNITED STATES TAX COUR T JEANNE E . AMARASINGHE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent DISAMODHA C . AMARASINGHE AND NARLIE AMARASINGHE, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket Nos . 14062-06, 15883-06 . Filed November 6, 2007 . P-H failed to pay…
  13. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999
    …w York for account No. 015-268675 was as follows: - 11 - Date Withdrawal Deposit Balance 8/27/85 $1,333.20 --- $53,352.07 8/27/85 50,000.00 --- 3,352.07 10/15/85 --- $1,127.20 4,479.27 11/25/85 --- 1,333.20 5,812.47 12/03/85 5,500.00 673.91 986.38 1/13/86 14,500.00 13,654.49 140.87 4/14/86 --- 1,059.80 1,200.67 10/07/8…
  14. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    one fluent in English knows that the word ‘includes’ cannot be assumed to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) . In sum, petitioner’s arguments have been rejected by the courts in hundreds of cases, and we will not di…
  15. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007
    … grant equitable relief, for abuse of discretion . Fernandez v . Commissioner , 114 T .C . 324, 330-333 (2000) ; Butler v . Commissioner , 114 T .C . 276, 292 (2000) . Section 6015(b ) Section 6015(b)(1) provides for relief from liability for tax attributable to an understatement if all five conditions set out in secti…
  16. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    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…
  17. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …oan 12/02, after loan withdrawal was made Ameritas BWS $167,000 $291,329 $98,246 #2477 Ameritas DSC 333,000 547,023 173,200 #2479 The SPD clarified that "[p]olicy cash values may not be pledged or assigned, because the participant has no right to them." -15- [*15] The Trust cut Alan two checks: one for $167,000, and th…
  18. T.C. Memo. 2025-1 — Matthew D. Hutcheson & Annette Hutcheson v. Commissioner
    IRCCourt RulingsJan 2, 2025related by meaning
    ively , petitioners are liable for a section 6662 accuracy - related penalty. We hold Mr. Hutcheson is liable for the fraud penalty . FINDINGS OF FACT W hen the Petition was timely filed , Mrs. Hutcheson resided in Idaho , and Mr. Hutcheson was incarcerated in California . 3 Some facts and exhibits have been deemed sti…
  19. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018related by meaning
    ners are liable under section 6662(a) and (b)(2) for an accuracy-related penalty on an underpayment due to a substantial understatement of income tax. Section 6662(a) imposes a 20% accuracy-related penalty on any portion of an underpayment of tax required to be shown on a return if, as provided by section 6662(b)(2), t…
  20. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …Admin. Regs. - 80 - The Commissioner doesn't like this sort of thing. See Notice 2004-8, 20041 C.B. 333; Summa Holdings, Inc. v. Commissioner (Summa I), T.C. Memo. 2015-119, at *15-*16. He says that non-arm's-length payments from a preexisting business to a related Roth IRA-owned entity are really distributions to shar…