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70 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2005-71 — Vincent A. Suarez, Jr. & Esther Suarez v. Commissioner
    IRCCourt RulingsJun 6, 2005related by meaning
    a matter of legislative grace, and the burden of clearly showing the right to the claimed deduction is on the taxpayer. INDOPCO, Inc. v. Commissioner , 503 U.S. 79, 84 (1992). We are bound by the Internal Revenue Code, and it is within the province of the legislature to decide the circumstances of inclusion, deductions…
  2. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    hould apply throughout ERISA including the tax provisions. Because the Department of Labor failed to issue final regulations on this point until 1992, petitioner contends that respondent is not in a position to argue that separate definitions of a fiduciary apply for the two titles. However, the absence of final regula…
  3. 83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act
    IRCFinal Rules (FR)Nov 15, 2018
    …k to Citation 96.   Id. Back to Citation 97.  Table 1A, page 5 (stating that in coverage year 2015, 177.5 million persons of all ages were covered by employer sponsored insurance, with 135.7 million of those being covered by private sector employers), available at https://www.dol.gov/​sites/​default/​files/​ebsa/​resea…
  4. 80 T.C. 789; 80 T.C. No. 40 — Benson v. Commissioner
    IRCCourt RulingsApr 26, 1983
    s from finding a gift where property worth $371,875 is exchanged for an annuity worth $177,500.92. See Estate of Bell v. Commissioner, 60 T.C. at 473. We also note that Marion did not seek to ascertain the cost of comparable commercial annuities before entering into the annuity agreement, a factor we have found to indi…
  5. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    rary purpose has been shown here. Because we are satisfied that our analysis of section 4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A. - 11…
  6. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … of State lawsuits that stem from allegations of deceptive practices resulting in financial losses.[177] For example, in 2018, the Ohio Office of Attorney General reported that Centene Corporation, which oversaw Ohio's Department of Medicaid prescription drug program, had engaged in spread pricing which cost the State …
  7. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …estimate that these proposed rules would affect 90,900 non-Federal governmental group health plans.[177] Of these plans, approximately 35.7 percent [178] (or 32,400) are self-insured,[179] and 64.3 percent (or 58,400) are fully funded.[180] 2. Participants, Beneficiaries, and Enrollees The Departments estimate that the…
  8. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    …3 Areas in which determination letters will not be issued 176 .04 Determination letter applications 177 .05 Review of determination letters 177 SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 178 .01 Scope of this section 178 .02 Scope of determination letters 178 .03 Design-based safe harbor 178 .04 Go…
  9. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    aling excise tax, but only because the self-dealing transaction was disclosed on the foundation return, which claimed that the transaction was exempt. We need not address whether the 6-year period of li.mitations would apply when a plan return fails to disclose a transaction but the excise tax attributable to that tran…
  10. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …ies agreed to an average price of $656,000 per finished lot and estimated lot-finishing co st s of $177,000 per lot. On the b as is of these terms, Mr. Duvall inferred a tract value of approximately $3.35 million after accounting for the parties’ cost estimates. In another portion of
  11. 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…
  12. Treas. Reg. § 1.72-7(d)(2) — Adjustment in investment where a contract contains a refund feature.
    IRCRegulationsJul 26, 2016
    …the investment in the contract of $25,000, results in an adjusted investment in the contract of $23,177.50. If A dies before receiving payments for 15 years and the remaining payments are made to B, his beneficiary, B shall exclude the entire amount of such payments from his gross income until the amounts so received b…
  13. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
  14. Treas. Reg. § 1.401(a)(9)-6(m)(4)(i)(B) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    … 540,283 26,482 519,151 2031 864,291 529,534 524,342 26,760 502,774 2032 819,740 512,829 507,801 27,177 485,652 2033 775,430 495,365 490,509 27,438 467,927 2034 731,620 477,286 472,606 27,853 449,433 1 $1,000,000 death benefit reduced 4.55 percent for withdrawal during 2028. 2 Notional account balance at end of precedi…
  15. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016related by meaning
    culating the required reduction in the section 415 dollar limitation. Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the age 45 limits for tax years 2002 through 2006 are correct. III. Petitioner's Liabilit…
  16. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  17. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971related by meaning
    g $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
  18. T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    ed on Schedule M, Part 2 of the estate tax return Q-TIP tre atment for the "Part B" trust. We find petitioner's position unpersuasive. The language of -10the transitional rule is explicit. The transitional rule precludes the unlimited marital deduction provided with the enactment of ERTA to an estate where: (1) The wil…
  19. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  20. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …s 62,046 = (( 1/3 ) × 244,378 Participants in Small Non-frozen DB Plans Under 2020 Safe Harbor + 57,177 Participants in Small Frozen DB Plans Under 2020 Safe Harbor) × (96.1% Pre-Statute E-Disclosure Rate−51.3% Post-Statute E-Disclosure Rate) 1 $0.05 $1.00 $65,149 Distribution of Statements for DC Plans 4,035,517 = 9,0…