Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 761 (not yet in the library — opens the official source)
73 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable…
    IRCFinal Rules (FR)Jul 19, 2010
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
  2. 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, 2006
    … to be treated as the owner of all or a portion of the trust under §§ 673 to 677. (8) Sections 101, 761, and 7701.—Definitions.—Whether, in connection with the transfer of a life insurance policy to an unincorporated organization, (i) the organization will be treated as a partnership under §§ 761 and 7701, or (ii) the …
  3. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    ng this amount. Subsequently, J.D. merged into Clarkston pursuant to section 368, and filed a final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the final return year of J.D. eliminated by book entry as a result of the merger. - 5 - Discussion Respondent’s …
  4. Rev. Proc. 2005-3 — 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, 2005
    … to be treated as the owner of all or a portion of the trust under §§ 673 to 677. (7) Sections 101, 761, and 7701.—Definitions.—Whether, in connection with the transfer of a life insurance policy to an unincorporated organization, (i) the organization will be treated as a partnership under §§ 761 and 7701, or (ii) the …
  5. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    nsation. He then used his 2011 income tax return in an attempt to "regain" his desired preferential tax treatment that he had earlier abandoned by not challenging Zave. We cannot presume that in an agreement to pay petitioner for completing two requirements Zave actually intended for the entire amount to be paid with r…
  6. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    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…
  7. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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…
  8. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    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.
  9. 29 C.F.R. § 4000.41 — What are these computation-of-time rules about?
    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…
  10. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  11. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986). The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
  12. 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…
  13. PLR 200109010 — Sale/Exchange
    IRCPrivate Letter RulingsMar 2, 2001related by meaning
    n believes a court would find section 4975 to be punitive in nature and, therefore, considered a penalty under the Bankruptcy Code. See , e.g. , In re MMR Holding Corp. , 1998 Bankr. LEXIS 1132 (Bankr. M.D. La. 1998) (for purposes of I.R.C. § 6601, section 4975(a) is a penalty because its aim is to punish wrongful cond…
  14. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    includible in income under section 61(a)(12) and subject to tax. However, this issue is moot because petitioners' debts were not discharged but rather extinguished, and thus petitioners' income was not from discharge of indebtedness. III. Accuracy-Related Penalty Section 6662(a) imposes an accuracy-related penalty equa…
  15. 122 T.C. No. 16 — Gregory Iannone v. Commissioner
    IRCCourt RulingsApr 19, 2004related by meaning
    longed to petitioner when he filed his bankruptcy petition is still encumbered in rem by a Federal tax lien. Respondent argues that a State law cannot operate to divest or exempt petitioner’s section 401(k) retirement account from the Federal tax lien. Respondent contends that collection by levy is appropriate. We agre…
  16. 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…
  17. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    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…
  18. PLR 201017056 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsApr 30, 2010
    … April 01, 2010 2:59:47 PM To: ------------------ Cc: Subject: RE: ERISA question The pr ovision 29 USC 1104(b) that you are referring to is section 404(b) of ERISA, that provides that no fiduciary may maintain the indicia of ownership of any assets of a plan outside the jurisdiction of the District Courts of the U.S.,…
  19. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    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…
  20. 78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-…
    IRCFinal Rules (FR)Nov 13, 2013
    …ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended. List of Subjects 26 CFR Part 54 Excise taxes Health care Health insurance Pensions Reporting and recordkeeping requirements 29 CFR Part 2590 Continuation c…