78 FR 72018 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 2, 2013
…High 3
if monthly benefit at URA is greater than—
From—
To—
2015
614
614
2,594
2,594
2016
627
627
2,651
2,651
2017
641
641
2,710
2,710
2018
655
655
2,769
2,769
2019
670
670
2,830
2,830
2020
685
685
2,893
2,893
2021
700
700
2,956
2,956
2022
715
715
3,021
3,021
2023
731
731
3,088
3,088
2024 or later
747
747
3,156
3,156
1…
IRCCourt RulingsDec 22, 2008related by meaning
to willful neglect . See Higbee
v . Commissioner , supra at 446-447 (stating that the taxpayer
bears the burden of proof regarding reasonable cause) . Accordingly, on this issue we sustain respondent's determination .
V . Section 6673(a)(1 )
Section 6673(a)(1) authorizes this Court to penalize up to
$25,000 a taxpayer …
IRCProposed Rules (FR)Proposed Nov 27, 2019
…burden is estimated to be 39,180 hours with an equivalent total annual cost of approximately $1,373,651. Table 8A—Estimated Annual Cost and Hour Burden per Health Insurance Issuer or TPA To Train Customer Service Representatives To Provide Assistance to Consumers Related to the Internet-Based Self-Service Tool
Occupati…
75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
lter transaction after May 17, 2006, and before January 1, 2007, the disclosure required by this section shall be filed on or before November 2, 2007. (4) No disclosure. Disclosure is not required with respect to any prohibited tax shelter transaction entered into by a tax-exempt entity on or before May 17, 2006.
(e) P…
IRCCourt RulingsOct 13, 2009related by meaning
Section 72(t) Additional Ta x
Section 72(t) imposes an additional tax on an individual
retirement plan distribution equal to 10 percent of the amount .included in gross income, subject to certain exceptions . Because
the ASLAC distribution is not includable in petitioner's gross
income, petitioner is not liable for th…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
IRCCourt RulingsMay 19, 1994
…nwald v. Commissioner, supra, would be followed. Woodson v. Commissioner, 73 T.C. 779 (1980), revd. 651 F.2d 1094 (5th Cir. 1981). At the time of our Woodson opinion, there was agreement amongst three different courts concerning the treatment under section 402(a)(2) of distributions from unqualified trusts. The Court o…
IRCCourt RulingsJan 14, 2013related by meaning
elated
penalty for the 2002, 2003, 2004, and 2005 tax years.
- 39 -
[*39] Subsection (a) of section 6662 imposes an accuracy-related penalty of 20% of any underpayment that is attributa le to causes specified in subsection (b).
Respondent asserts that one or botli of two causes justify the imposition of the
penalty for…
Rev. Rul. 2003-83 — Minimum funding; entry age normal; reasonableness. This ruling addresses two situations where the aggregate entry age normal method of funding is not a reasona… IRCRevenue RulingsJul 28, 2003
… present value (as of each participant's entry age) of the participant's projected benefits is $125,651.72. The sum, for all active participants, of the present value (as of each participant's entry age) of a level annuity of 1 per year payable from the participant's entry age until the participant's retirement age is …
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…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
IRCCourt RulingsFeb 28, 2024related by meaning
by the decision of the Tax Court which has become final shall be assessed and
shall be paid upon notice and demand from the Secretary .”). In short,
5 For a discussion of the disputed issues of fact on this point, see the Order
issued by the Court on April 8, 2019, denying each party’s Motion for Partial Summary
Judgme…
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
80 FR 57709 — Reliance Standards for Making Good Faith Determinations IRCFinal Rules (FR)Sep 25, 2015related by meaning
uch purpose with small grants. Therefore, a Regulatory Flexibility Analysis under the Regulatory Flexibility Act (5 U.S.C. chapter 6) is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking preceding these regulations was submitted to the Chief Counsel for Advocacy o…
IRCCourt RulingsFeb 25, 2016related by meaning
…is entitled to any deductions beyond those already allowed by
respondent.
V. Form 5329 and Section 6651(a)(1) Addition to Tax
Failure to file a tax return on the date prescribed leads to a mandatory
addition to tax unless the taxpayer shows that such failure was due to reasonable
cause and not due to willful neglect. S…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… a result, DB Beneficiaries will not be included in calculations discussing “beneficiaries”. See 29 USC 1025 for more information.
3
Bureau of Labor Statistics, Job Opening and Labor Turnover. Table A, Total Private. February 2025. Most recent release can be found here:
https://www.bls.gov/news.release/pdf/jolts.pd…
IRCCourt RulingsDec 30, 2013related by meaning
.
- 26 -
return or in a statement attached to the return and there is a reasonable basis for
the taxpayer's treatment of the item. Sec. 6662(d)(2)(B). The Commissioner bears the initial burden of production with respect to the
taxpayer's liability for the section 6662 penalty. Sec. 7491(c). At trial the
Commissioner mu…
IRCCourt RulingsNov 12, 1997related by meaning
iling extensions
constituted his sole defense to the section 6651 (a)(1) addition to
tax, petitioner has not shown that his failure to timely file his 1991 tax return was due to reasonable cause and not willful
neglect. See C rocker v. Commissioner
, supra
at 913. Accordingly,
we hold that petitioner is liable for the …
IRCCourt RulingsDec 11, 2003related by meaning
credit or refund
allowable for purposes of secs. 6011(a), 6511(b), and 6512(b)),
affd. 5 F.3d 195 (7th Cir. 1993); Martin Fireproofing v.
Commissioner , 92 T.C. 1173, 1192 (1989) (addition to tax for
failure to timely file under sec. 6651(a)(1) and filing of
information return under sec. 6033); Beard v. Commissioner
, …