91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
efits Manager prepares Notice of Internet Availability (First year)
21,586
0.25
193.15
1,042,334
−3,127,002
21,586
0.5
193.15
2,084,668
−2,084,668 Primary Assumption
21,586
1
193.15
4,169,336
0
21,586
2
193.15
8,338,672
4,169,336
21,586
3
193.15
12,508,008
8,338,672
3. Initial Notice of Default E-Delivery and R…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
IRCCourt RulingsMar 22, 2007related by meaning
ddition to tax must be
sustained.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or
groundless or the taxpayer has instituted or pursued the
proceeding primarily for delay. Respondent has n…
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
MAY 13 2014
Uniform Issue List: 408.03-00, 2501.00-00, 4973.00-00, 4974.00-00
* * *
* * *
* * *
Legend:
Taxpayer A
=
* * *
Decedent 8
=
* * *
Decedent c
=
* * *
Charity D
=
* * *
Trust
=
* * *
Financia…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
note, Pub. L. 114-74 at § 701. Subparts H and I issued under 8 U.S.C. 1101(a)(15)(H)(i)(b) and (b1), 1182(n), 1182(t), and 1184; 29 U.S.C. 49
et seq.; sec 303(a)(8), Pub. L. 102-232, 105 Stat. 1733, 1748 (8 U.S.C. 1182 note); and Title IV, Pub. L. 105-277, 112 Stat. 2681; and 28 U.S.C. 2461 note, Pub. L. 114-74 at § 70…
ERISARegulationsOct 1, 2020related by meaning
(j) (j) Liability. (1) If more than one person is responsible as administrator for the failure to file the report, all such persons shall be jointly and severally liable with respect to such failure.
(j)(2) (2) Any person against whom a civil penalty has been assessed under section 502(c)(5) pursuant to a final order, …
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…
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 …
IRCCourt RulingsFeb 4, 1974related by meaning
tion 401(c) (1) made under a trust or plan described in paragraph (1) or (2) shall be considered to be contributions or payments made by the decedent. For purposes of this subsection, amounts payable under chapter 73 of title 10 of the United States Code are attributable to payments or contributions made by the deceden…
IRCPrivate Letter RulingsDec 1, 2006related by meaning
c Oil Producing Co. v. United States
, 35 F. Supp. 766 (Ct.
Cl. 1940)). Further, an ov erpayment of tax can exist only if the amount remitted with the request for an extension of time to file exceeds the final tax liability shown on Form 706. Id.
Section 7422 authorizes a taxpayer to institute a civil action for refund…
80 FR 54980 — Reportable Events and Certain Other Notification Requirements PBGCFinal Rules (FR)Sep 11, 2015related by meaning
added to the aggregate unpaid balance of all preceding such payments for which payment was not made when due (including interest), exceeds $1 million. (1) Form 200 must be filed with PBGC no later than 10 days after the due date for any required payment for which payment was not made when due.
(2) If a contributing spo…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
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…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
IRCCourt RulingsJan 14, 2013related by meaning
sonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% section 4972 excise tax applies to
that extent. V. Section 6651(a)(1) and (2) Additions to Tax
Respondent contends that the corporation is liable for section 6651(a)(1)
failure to file additions to tax of $10,050.95 a…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
IRCCourt RulingsApr 19, 2004related by meaning
the payment of such tax. * * *
Section 6334(a) exempts from levy: (1) Wearing apparel and
school books; (2) fuel, provisions, furniture, and personal effects; (3) books and tools of a trade, business, or profession;
(4) unemployment benefits; (5) undelivered mail; (6) certain
annuity and pension payments; (7) workmen’…