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76 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …24 participants 25 to 99 participants Less than 100 participants ERISA-Covered Group Health Plans 1,407,999 606,407 562,404 2,576,811 2. TPAs and Issuers In order to estimate the direct impact on small plans the Department looks at the cost to issuers and TPAs that assist group health plans comply with the proposed rul…
  2. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  3. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  4. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …he amounts listed below: Itein Reported Disallowed Conceded At issue Legal and professional $1,000 $407 --- $407 Travel 8,489 1,054 --- 1,054 ¹° Petitioners claimed several other Schedule C deductions that respondent
  5. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …xable income. 25 26 CFR § 1.482-1(b)(1) (1971). Commissioner v. First Sec . Bank , 405 U.S. at 403- 407. The statutory provision referred to in First Security Bank was section 482 of the Internal Revenue Code of 1954. The regulation referred to in First Security Bank was 26 C.F.R. sec. 1.482-1 (1971). When citing and q…
  7. 76 FR 34590 — Bankruptcy Filing Date Treated as Plan Termination Date for Certain Purposes; Guaranteed Benefits; Allocation of Plan Assets; Pension Protection Act of 2006
    PBGCFinal Rules (FR)Jun 14, 2011
    …n 404 of PPA 2006. PBGC intends to do so in a future rulemaking. Substantial-Owner Benefits Section 407 of PPA 2006 amended section 4022(b)(5) of ERISA, which previously provided a special phase-in rule for PBGC's guarantee of the benefits of “substantial owners,” who were generally defined as those owning more than 10…
  8. 75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans
    ERISAProposed Rules (FR)Proposed Aug 30, 2010
    …an exemption specifically applies to such conduct. To supplement these provisions, sections 406 and 407(a) of ERISA impose restrictions on the nature and extent of plan investments in assets such as “employer securities” (as defined in section 407(d)(1) of ERISA) and “employer real property” (as defined in section 407(…
  9. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…
  10. I.R.C. § 4975(f)(11)(B)(i) — Tax on prohibited transactions
    IRCCode / StatuteJan 6, 2025
    …its affiliates that involves the acquisition or sale of an employer security (as defined in section 407(d)(1) of the Employee Retirement Income Security Act of 1974) or the acquisition, sale, or lease of employer real property (as defined in section 407(d)(2) of such Act). (f)(11)(B)(ii) (ii) Knowing prohibited transac…
  11. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979related by meaning
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
  12. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. (b) Retroactivity of R…
  13. 38 T.C. 312 — Hydro Molding Co. v. Commissioner
    IRCCourt RulingsMay 28, 1962related by meaning
    ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
  14. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
    IRCNoticesJul 8, 2024related by meaning
    nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
  15. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
  16. 29 C.F.R. § 2550.407d-5(a) — Definition of the term “qualifying employer security”.
    ERISARegulationsJan 1, 2017
    (a) (a) In general. For purposes of this section and section 407(d)(5) of the Employee Retirement Income Security Act of 1974 (the Act), the term “qualifying employer security” means an employer security which is: (a)(1) (1) Stock; or (a)(2) (2) A marketable obligation, as defined in paragraph (b) of this section and s…
  17. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  18. 29 C.F.R. § 2550.407d-6(a) — Definition of the term “employee stock ownership plan”.
    ERISARegulationsJan 1, 2017
    …)(1) (1) Type of plan. To be an “ESOP” (employee stock ownership plan), a plan described in section 407(d)(6)(A) of the Employee Retirement Income Security Act of 1974 (the Act) must meet the requirements of this section. See section 407(d)(6)(B). (a)(2) (2) Designation as ESOP. To be an ESOP, a plan must be formally d…
  19. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  20. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998
    T.C. Memo. 1998-407 UNITED STATES TAX COURT STEPHEN NEAL SWIHART, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2966-98. Filed November 13, 1998. Stephen Neal Swihart, pro se. Julie L. Payne , for respondent. MEMORANDUM OPINION WOLFE, Special Trial Judge : This case was heard pursuant to the pr…