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89 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    er. Mrs. Gebman did not provide any evidence that persuades us that she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file amendment to petition filed August 28, 2019. VI. Section 6662(a) Penalties Section 6662(a) an…
  2. PLR 201945005 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 8, 2019
    … with the r equirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable PLR - 101326-19 2 contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of se ction 4974(c). The Contract is comp…
  3. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    period starts with the due date of the return. Sec. 6501(b)(1). - 13 - [*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency. S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment provi…
  4. PLR 201945007 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 8, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of s ection 4974(c). PLR - 101340-19 2 The Contract is comp…
  5. Treas. Reg. § 301.6652-1(f) — Failure to file certain information returns.
    IRCRegulationsDec 19, 2016related by meaning
    (f) (f) Showing of reasonable cause. The amount imposed by subsection (a), (b), or (c) of section 6652 shall not apply with respect to a failure to file a statement within the time prescribed if it is established to the satisfaction of the district director or the director of the Internal Revenue Service Center that su…
  6. PLR 201945008 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 8, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan with in the meaning of section 4974(c). PLR - 101341-19 2 The Contract is comp…
  7. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …ificant comments.” See, e.g ., La. Fed. Land Bank Ass’n , 336 F.3d at 1080; Balt. Gas & Elec. Co ., 817 F.2d Cir. 1991) ; Hussion v. Madigan , 950 F.2d 1546, 1554 (11th Cir. 1992) ; Huawei Techs. USA, Inc. v. FCC , 2 F.4th 421, 449 (5th Cir. 2021) . 323 at 116. Treasury was required to respond to these comments because…
  8. PLR 201945009 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 8, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable contrac ts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). PLR - 101342-19 2 The Contract is comp…
  9. 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…
  10. PLR 201946002 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    …ments of section 72(s). One of the Contracts is a PLR - 101289-19 2 variable contract under section 817(d), while the other Contract is not a variable contract under section 817(d). The Contract is n ot part of any qualified retirement plan within the meaning of section 4974(c). The Contract is comprised of an accumula…
  11. PLR 201946003 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    … with the re quirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the contracts are not variable PLR - 1013 25-19 2 contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of sec tion 4974(c). The Contract is com…
  12. 81 FR 47496 — Annual Reporting and Disclosure
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    … estimates that the regulations and forms revisions proposed today will impose an annual burden of $817.0 million on 2.97 million filers, for a total increase of $328.8 million annually. ( printed page 47516) Table 2—Summary of Annual Costs: Current Requirements vs. Proposed Requirements   Total annual costs (millions)…
  13. PLR 201946004 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    … with the requirements of section 72(s). One of the Contracts is a variable co ntract under section 817(d) while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). PLR - 101343-19 2 The Contract is compri…
  14. PLR 201946005 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). PLR - 101344-19 2 The Contract is compr…
  15. PLR 201946006 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    … with the requirements of section 72(s). One of the Contracts is a variable con tract under section 817(d), while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). PLR - 101345-19 2 The Contract is compr…
  16. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    n is subject to section 404. It is difficult, if not impossible, to discuss deferring receipt of compensation without focusing on the time of payment. We also reject petitioner's contention that the case at hand is similar to that in Minahan v. Commissioner, 88 T.C. 492 (1987). We held, in that case, that the Secretary…
  17. PLR 201946008 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). PLR - 106625-19 2 The Contract is compr…
  18. I.R.C. § 501(c)(18)(D)(iv) — Exemption from tax on corporations, certain trusts, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(18)(D)(iv) (iv) the requirements of section 401(a)(30) are met. (c)(19) (19) A post or organization of past or present members of the Armed Forces of the United States, or an auxiliary unit or society of, or a trust or foundation for, any such post or organization— [(20) Repealed. Pub. L. 113–295, div. A, title II,…
  19. PLR 201946011 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 15, 2019
    …ith the requirements of section 72(s). ------ of the Contracts is a variable contract under section 817(d), while ----- of the Contracts are not variable contracts under section 817(d). The Contract is not part of any qualified retirement plan wit hin the meaning of section 4974(c). PLR - 106624-19 2 The Contract is co…
  20. PLR 201948002 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 29, 2019
    …g with the requirements of section 72(s). One of the Contracts is a variable contract under section 817(d), while two of the Contracts are not variable PLR - 101324-19 2 contracts under section 817(d). The Contract is not part of any qualified retirement plan within the meaning of section 4974(c). The Contract is compr…