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92 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1996-224 — Richard L. & Marjorie A. Freese v. Commissioner
    IRCCourt RulingsMay 16, 1996
    …pondent. MEMORANDUM OPINION GOLDBERG, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Respondent determined a deficiency in petitioners' Federal income tax for 1990 in the amount of $793. The sole issue for decision is 2 2 The record does not provide a clear expl…
  2. 84 FR 26605 — Exception for Interests Held by Foreign Pension Funds
    IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
    er means and the transferor was, in fact, a foreign person, then the transferee is subject to the liability imposed by section 1445 and § 1.1445-1(e). (i) A transferee is in no event required to rely upon other means to ascertain the non-foreign status of the transferor and may demand a certification of non-foreign sta…
  3. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    …ase was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and - 2 - 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule referenc…
  4. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …pondent. MEMORANDUM OPINION GOLDBERG, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Respondent 2 determined a deficiency in petitioner's Federal income tax for the year 1993 in the amount of $2,972 and an accuracy-related penalty in the amount of $534 pursuant …
  5. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    U.S.C. 1108), 112 Stat. 2061; 25 U.S.C. 1647b. 2. Section 890.114 is amended by revising paragraph (a) to read as follows: § 890.114 Surprise billing. (a) A carrier must comply with requirements described in 26 CFR 54.9816-3, 54.9816-3T through 54.9816-6T, 54.9816-6A, 54.9816-6, 54.9816-8T, 54.9816-8, 54.9817-1T, 54.98…
  6. T.C. Memo. 1998-172 — Richard S. & Bernice F. Roberts v. Commissioner
    IRCCourt RulingsMay 11, 1998
    …M OPINION NAMEROFF, Special Trial Judge : This case was heard pursuant to the provisions of section 7443A(b)(3) 1 and Rules 180, 181, and 182. - 2 - Respondent determined a deficiency in petitioners’ 1994 Federal income tax in the amount of $3,451. This case was submitted fully stipulated, and the sole issue to be deci…
  7. Treas. Reg. § 54.6011-1(b) — General requirement of return, statement, or list.
    IRCRegulationsDec 30, 2016related by meaning
    (b) (b) Tax on prohibited transactions. Every disqualified person (as defined in section 4975(e)(2)) liable for the tax imposed under section 4975(a) with respect to a prohibited transaction shall file an annual return on Form 5330 and shall include therein the information required by such form and the instructions iss…
  8. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
    IRCCourt RulingsJan 21, 1997
    …M OPINION CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and…
  9. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999
    … AND OPINION ARMEN, Special Trial Judge : This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. 1 - 2 - (...continued) the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Petitione…
  10. 29 C.F.R. § 2570.34(f)(11)(i)(E) — Information to be included in every exemption application.
    ERISARegulationsApr 8, 2024related by meaning
    (f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or (f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
  11. T.C. Memo. 1997-108 — Hugo Madioni & Susanne J. Nicolai v. Commissioner
    IRCCourt RulingsMar 3, 1997
    …ION PANUTHOS, Chief Special Trial Judge : This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, - 2 - 1 All section references are to the Internal Revenue Code in effect for the tax year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 181, and 182. 1 Re…
  12. T.C. Memo. 1996-146 — Lloyd Patterson v. Commissioner
    IRCCourt RulingsMar 25, 1996
    …respondent. MEMORANDUM OPINION PAJAK, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182. All section numbers refer to the Internal Revenue Code in effect for the taxable year in issue. All rule numbers refer to the Tax Court Rules of Practice and Procedure. Respondent …
  13. T.C. Memo. 1996-278 — Donald G. Russell v. Commissioner
    IRCCourt RulingsJun 17, 1996
    …ndent. MEMORANDUM OPINION COUVILLION, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) 1 and Rules 180, 181, and 182. Respondent determined a deficiency in petitioner's 1992 Federal income tax in the amount of $279. The sole issue for decision is whether unemployment benefits received by petiti…
  14. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    Form 886-A,Explanation of Items); Form 870, Waiver of Restriction on Assessments and Collection of Deficiency in Tax and Acceptance of Overassessment; notices of proposed deficiency that allow the taxpayer an opportunity for review in the Office of Appeals (30-day letters); notices pursuant to section 6213(b) (mathemat…
  15. T.C. Memo. 1996-231 — Charles E. King v. Commissioner
    IRCCourt RulingsMay 22, 1996
    …pondent. MEMORANDUM OPINION GOLDBERG, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Respondent determined a deficiency in petitioner's Federal income tax for 1990 in the amount of $672. The issues are: (1) Whether petitioner is entitled to deduct expenses attri…
  16. 88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction
    IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
    the treaty jurisdiction. VI. Purpose of Proposed Regulation On March 3, 2022, the Sixth Circuit issued an order in Mann Construction v. United States, 27 F.4th 1138, 1147 (6th Cir. 2022), holding that Notice 2007-83, 2007-2 C.B. 960, which identified certain trust arrangements claiming to be welfare benefit funds and i…
  17. T.C. Memo. 1996-517 — Jeffery Allen Robinson v. Commissioner
    IRCCourt RulingsNov 25, 1996
    …ndent. MEMORANDUM OPINION COUVILLION, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) 1 and Rules 180, 181, and 182. Respondent determined a deficiency of $1,895 in petitioner's Federal income tax for 1992 and the 10-percent additional tax on - 2 - 2 Respondent determined a reduction of $682 i…
  18. 80 FR 22010 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and B…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    he records necessary to enable the persons described in Section V(b) to determine whether the conditions of this exemption have been met, except that: (1) If the records necessary to enable the persons described in Section V(b) below to determine whether the conditions of the exemption have been met are lost or destroy…
  19. T.C. Memo. 1998-379 — Dale Reid Edmonds v. Commissioner
    IRCCourt RulingsOct 20, 1998
    …ndent. MEMORANDUM OPINION COUVILLION, Special Trial Judge : This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Respondent determined a deficiency of $418 in petitioner's Federal income tax for 1994. - 2 - The issues for decision are: (1) Whether petitioner is entitled to a $2,000 deducti…
  20. Rev. Proc. 2014-32 — This revenue procedure establishes a pilot program providing administrative relief to plan administrators and plan sponsors of certain retirement plans from th…
    IRCRevenue ProceduresJun 2, 2014related by meaning
    edure should be mailed to: Internal Revenue Service Employee Plans Delinquent Filer Program EP Classification 9350 Flair Drive El Monte, CA 91731-2828 .05. Private delivery services. Certain private delivery services designated by the Service can be used to meet the rule that timely mailing is treated as timely filing/…