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75 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    rm × 5.8 percent paper) + (11,000 Annual Statement × 5.8 percent paper) + (11,000 Report of Commissions Paid × 5.8 percent paper) = 1,943 disclosures. Back to Citation 52.  5 U.S.C. 601 et seq. Back to Citation 53.  5 U.S.C. 601(2), 603(a); see also 5 U.S.C. 551. Back to Citation 54.  Public Law 104-4, 109 Stat. 48 (Ma…
  2. 95 T.C. 364; 95 T.C. No. 26 — Wood v. Commissioner
    IRCCourt RulingsSep 27, 1990related by meaning
    . United States, 872 F.2d 564, 568-570 (3d Cir. 1989). Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
  3. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  4. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  5. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  6. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024related by meaning
    n 987 regulations”), including which entities are subject to the regulations, rules relating to elections under section 987, and other rules. A. Scope Under proposed § 1.987-1(b)(1), the section 987 regulations would apply to all taxpayers, subject to a de minimis rule for pass-through entities with minimal U.S. owners…
  7. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    004 made an excess contribution of $25,132,892 to his individual retirement account (IRA). Section 4973(a) 1 imposes an excise tax “in an amount equal to 6 percent of the amount of the excess contributions” that a taxpayer makes to an IRA in any given year. This tax continues to apply for future years, until such time …
  8. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    ust decide (1) whether section 4979A(a) imposes an excise tax on petitioner for its taxable year 2005 and (2) if so, whether the period of limitations under section 4979A(e)(2)(D) has expired for assessing that tax for that year. We turn first to whether section 4979A(a) imposes an excise tax on petitioner for its taxa…
  9. TR 2013-03 — Technical Release 2013-03
    ERISADOL Technical ReleasesSep 13, 2013
    .R. §54.9831-1(c)(3)(v), 29 C.F.R. §2590.732(c)(3)(v), and 45 C.F.R. §146.145(c)(3)(v). D. Affordable Care Act Guidance 1. Market Reforms – In General The Affordable Care Act contains certain market reforms that apply to group health plans (the market reforms). (2) In accordance with Code § 9831(a)(2) and ERISA §732(a)…
  10. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    trates actual knowledge by petitioner of the . IRA distribution, at the time she signed th e 6 The five criteria of sec . 6015(b)(1) are conjunctive . Having concluded that sec . 6015(b)(1)(C) is not satisfied, we need not, and do not, discuss the criteria of the other subsections of sec . 6015(b)(1) . - 11 - return . …
  11. 88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements
    IRCProposed Rules (FR)Proposed Aug 30, 2023related by meaning
    s.gov (preferred) or by telephone at (202) 317-6901 (not a toll-free number) by at least November 15, 2023. Statement of Availability of IRS Documents Guidance cited in this preamble is published in the Internal Revenue Bulletin and is available from the Superintendent of Documents, U.S. Government Publishing Office, W…
  12. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026related by meaning
    acted in good faith with respect to such portion. ” Unlike the reasonable cause and good faith exception found in section 6664(c), Congress placed the adequate disclosure exception in section 6662(d), with no text indicating that it was meant to apply to multiple section 6662 penalties. The reason for t his is apparent…
  13. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ds of thousands of dollars in DISC commissions each year from a well-established business, and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount. -28IV. Section 6662(a) Penalty Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
  14. 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…
  15. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012related by meaning
    ctive for determinations made after October 16, 2006, this Court has jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v. Commissioner, 130 T.C. 44, 48 & n.4 (2008). - 6 - Respondent does not dispute that petit…
  16. 83 FR 7437 — Short-Term, Limited-Duration Insurance
    IRCProposed Rules (FR)Proposed Feb 21, 2018
    …054. Back to Citation 13.  Sections 2722 and 2763 of the PHS Act, section 732 of ERISA, and section 9831 of the Code provide that the respective requirements of title XXVII of the PHS Act, part 7 of ERISA, and Chapter 100 of the Code generally do not apply to certain types of benefits, known as “excepted benefits.” Exc…
  17. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    r Federal or state law; or ( printed page 14744) (ii) A statement describing the applicable investigation, examination, litigation or controversy; and (12)(i) Either a statement that, within the last 13 years, the independent fiduciary has not been either convicted or released from imprisonment, whichever is later, as …
  18. T.C. Summary Opinion 2006-8 — Terry Fred Burnham v. Commissioner
    IRCCourt RulingsJan 26, 2006related by meaning
    ate are treated as payments not received as an annuity and are taxable. Sec. 72(e)(2)(A). There is simply not sufficient information in this record to reach a conclusion whether some portion of the $8,000 payment is not includable in income. The Court and respondent encouraged - 10 - petitioner to provide sufficient in…
  19. 87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities
    IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
    SSES: Commenters are strongly encouraged to submit public comments electronically. Submit electronic submissions via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG-100442-22) by following the online instructions for submitting comments. Once submitted to the Federal eRulemaking Portal, comm…
  20. 81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Oct 31, 2016
    …ich applies for policy years beginning on or after January 1, 2017. Back to Citation 23.  26 CFR 54.9831-1(c)(3)(v), 29 CFR 2590.732(c)(3)(v), 45 CFR 146.145(b)(3)(v). Back to Citation 24.  PHS Act section 2722(c)(1), ERISA section 732(c)(1), Code section 9831(c)(1). Back to Citation 25.  26 CFR 54.9831-1(c)(5)(i)(C), …