110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998
…s determination that an employer's pension
plan failed to qualify under section 401(a). H. Rept. 93-807, at
106 (1974), 1974-3 C.B. (Supp.) 236, 341. Instead, the employer
under the then-existing law could seek judicial review of
respondent's action after the employer made contributions to its
plan, claimed the contrib…
IRCCourt RulingsDec 10, 2012
…enefits under the plan
even if he has only forfeitable rights to those benefits." H.R. Rept. No. 93-807, at
129 (1974), 1974-3 C.B. (Supp.) 236, 364. Section 1.219-2(b),.Income Tax Regs.,
concerns defined benefit plans and, in particular, states: "[A]n individual is an
active participant in a defined benefit plan if fo…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
…minations of whether their plans are qualified without first paying the deficiency. H. Rept. No. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 340-341, explains more fully the need for sec. 7476.
SEC. 7476. DECLARATORY JUDGMENTS.
(b) Limitations.—
(1) Petitioner. — A pleading may be filed under this section only by a petitio…
IRCCourt RulingsFeb 18, 1997
…opportunity to set aside at least some retirement savings on a tax-sheltered basis. See H. Rept. 93-807 (1974), 1974-3 C.B.
(Supp.) 236, 361; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80,
210. Under the statutory framework thus established, individuals
could obtain a limited deduction for amounts contributed to
indiv…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
S corporations and other pass-through entities in the same manner as such rules apply to partnerships” except as the Secretary may otherwise provide. Section 170(h)(7)(B) defines the terms “relevant basis” and “modified basis,” section 170(h)(7)(C), (D), and (E) provide three exceptions to the Disallowance Rule, and s…
IRCCourt RulingsMar 23, 1987
…o be sure that the general standards provided in these three areas are the same. * * * [H. Rept. 93-807, at 1 (1974), 1974-3 C.B. (Supp.) 236.] Although the fiduciary standards of ERISA section 403(c) were not enacted as part of the Internal Revenue Code, the statute is an integrated whole which, absent clear expressio…
IRCCourt RulingsFeb 18, 1998
…o facilitate portability of pensions. Conf. Rept.
93-1280 (1974), 1974-3 C.B. 415, 502; H. Rept. 93-807 (1974),
1974-3 C.B. (Supp.) 236, 265. The purpose of the IRA-to-IRA
transfers was to permit flexibility with respect to the
investment of an IRA. H. Rept. 93-807, supra
, 1974-3 C.B.
(Supp.) at 374; S. Rept. 93-383 (…
IRCCourt RulingsMay 30, 1984related by meaning
ents of section 2039(c)(3).
Due to concessions and in order to reflect petitioner’s claim for an overpayment,
Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
IRCRegulationsDec 30, 2016related by meaning
(a) (a) [Reserved]
I.R.C. § 6652(f)(3) — Failure to file certain information returns, registration statements, etc. IRCCode / StatuteJan 24, 2020related by meaning
(f)(3) (3) Limitation The amount determined under paragraph (2) with respect to any person for failing to meet the requirements of section 6039C for any calendar year shall not exceed the lesser of— For purposes of the preceding sentence, fair market value shall be determined as of the end of the calendar year (or, in …
REG-124988-05 — Proposed regulations under section 412 of the Code provide guidance regarding mortality tables to be used in determining the current liability of a qualified d… IRCProposed Rules (FR)Proposed Dec 19, 2005
…ction 412(l)(7) must be based on the prevailing commissioners’ standard table (described in section 807(d)(5)(A)) used to determine reserves for group annuity contracts issued on January 1, 1993. For purposes of section 807(d)(5), Rev. Rul. 92-19, 1992-1 C.B. 227, specifies the prevailing commissioners’ standard table …
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
mit any such crimes or a crime in which any of the foregoing crimes is an element; or a crime that is identified or described in ERISA section 411; or (B) by a foreign court of competent jurisdiction as a result of any crime, however denominated by the laws of the relevant foreign or state government, that is substanti…
IRCCourt RulingsJan 19, 2010
…. income pu t
Petitioner,timely,filed a2006-Federalincome .tax . return,
properly reporting the $70,807 in total distributions from .the
APT retirement plan and properly, including $50,000 of the tota l
the $20,807-as-a rollover distribution .
balance due of $1,999 beyond the $10,000 in Federal income ta x
withholding …
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
ements prescribed in Treasury regulations. Section 4082(f)(1) provides that the exemption in section 4082(a) generally does not apply to the LUST tax. Section 48.4082-1 and Notice 2005-80, 2005-2 C.B. 953, provide rules and conditions for the exemption provided by section 4082(a) to apply to the removal, entry, or sale…
IRCCourt RulingsJun 1, 2009related by meaning
account of the employee's disability ; (4) as part of a serie s
e for life ; (5) to a
employee after separation from service after attainment of ag A substantially equal periodic payments m
55 ; (6) as dividends paid with, respect to corporate stoc k
described in section 404(k) ; (7) to an employee for medica l
or (8)…
IRCCourt RulingsMar 9, 1982
tute an impermissible discrimination. * * * [H. Rept. 93-807, supra, 1974r-3 C.B. (Supp.) at 285; S. Rept. 93-383, supra, 1974-3 C.B. (Supp.) at 122.] Additionally, we must remember that the remedial amendment described was engrafted on legislation enacted over the last four decades with the consistent purpose of encou…
ERISARegulationsApr 8, 2024related by meaning
(a) (a) The rules of procedure set forth in this subpart apply to applications for prohibited transaction exemptions issued by the Department under the authority of:
(a)(1) (1) Section 408(a) of the Employee Retirement Income Security Act of 1974 (ERISA);
(a)(2) (2) Section 4975(c)(2) of the Internal Revenue Code of 19…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-7 Rev. Rul. 2006-7
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2006.
T.D. 9238 T.D. 9238
Temporary and proposed regul…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title: