IRCRegulationsSep 9, 2016
… 104(d) of PPA '06, which reflects amendments made by section 202(b)(2) of PRA 2010, Public Law 111-192, 124 Stat. 1280 (June 25, 2010)) that applies section 430 to the first plan year beginning on or after January 1, 2008 has a pre-effective plan year that is the last plan year beginning before January 1, 2008 and a s…
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…
PBGCRegulationsSep 15, 2025
…rvation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010, Public Law 111-192, dealing with eligible charity plans and plans of certain rural cooperatives, the plan must meet the requirements in paragraph (a)(5) of this section (in connection with the actuarial valuation report) in effect as o…
IRCCourt RulingsSep 25, 2019
…urn, he has
made no election to itemize his deductions. See Salati v. Commissioner, T.C.
Memo. 1989-192. If an individual does not file a return and, as a result, the
Commissioner prepares a substitute return, then the individual has made no
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…nts Pre-Statute × 10% Receiving Duplicate Statements per Year
5.00
0.05
1.00
43,957
Total
36,342
45,192
1
These costs were displayed as transfers from plans to participants in Table 10 of the RIA. However, since this impact on small plans is viewed as a cost from the small plans point of view the share of the transfer…
IRCCourt RulingsOct 9, 1990related by meaning
o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
IRCCourt RulingsDec 15, 2009
…istribution due to,disability . The
fair market value of the IRA account at the end of 2005 was
$43,192 .
From 2001 through 2003 Ms . Welker received wages from
employment at a bookstore . During 2003 and 2004 Ms . Welker
received unemployment compensation .
For 2005 Ms . Welker received a Form W-2, Wage and Tax
Statem…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
34 T.C. 851 — West Virginia Steel Corp. v. Commissioner IRCCourt RulingsAug 15, 1960related by meaning
ty is computed on the net amount of tax due on the return rather than on the gross amount of tax required to be shown on the return. [Emphasis added.] Beyond the bare assertion just quoted, we have discovered no authority in support of the existence of the alleged “administrative rule.” Of course, it would seem reasona…
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…
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
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
IRCCourt RulingsOct 11, 1957
…e constitutional unless its repugnancy to the Constitution clearly appears. Buttfield v. Stranahan, 192 U. S. 470, 492 (1904). This is particularly true of a revenue act of Congress, since the power to tax is one of the great powers upon which the whole national fabric is based. Nicol v. Ames, 173 U. S. 509, 515 (1899)…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
IRCCourt RulingsJan 14, 2013
… (27,771)
1987 33,357 26,769 6,588 7,894 29,077 (21,183)
1986 32,182 15,521 16,661 7,572 18,764 (11,192)
1985 31,048 13,000 18,048 7,264 12,923 (5,659)
1984 29,955 6,000 ! 23,955 6,968 -0- 6,968
-26-
[*26]
1983 28,899 -0- 28,899 6,684 -0- 6,684
1982 27,881 -0- 27,881 6,412 -0- 6,412
1981 26,899 -0- 26,899 6,151 -0- 6,1…
IRCCourt RulingsApr 11, 2012
…ents waived); Muhich v. Commissioner, 238 F.3d 860, 864 n.10 (7th Cir.
2001), aff g T.C. Memo. 1999-192.
3
- 54 -
evidence indicating that it is appropriate to impose the penalty. See Higbee v.
Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his
burden of production, however, the burden of proof rem…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
IRCCourt RulingsJun 17, 1997
…35 -
Total Out
Total In
Accounting fees $4,184 ---
Actuarial gains --- $252,977
Administrative fees 192,000 ---
Death benefit 3,398 ---
Death forfeitures --- 474,839
Expense allocations 22,939 ---
Interest earned --- 48,581
Legal fees 387,990 256
Miscellaneous 2,011 ---
Trustee fees 4,203 ---
Unrealized loss 17,035
---…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
IRCCourt RulingsMar 20, 1997
…r
Deficiency
Sec. 6653(a)(1)
Sec. 6662(a)
1988 $19,469 $973 ---
1989 10,846 --- $2,040
1990 962 --- 192
Dura-Craft, Inc.--docket No. 20560-94
Taxable Year
Addition to Tax and Penalty
Ending
Deficiency
Sec. 6653(a)(1)
Sec. 6662(a)
10/31/88 $15,968 $798 ---
10/31/89 93,410 --- $3,591
Unless otherwise indicated, all secti…
IRCCourt RulingsNov 30, 2006
…t plan in 2002.
Conclusion
The tax code is complex, see generally Cheek v. United
States
, 498 U.S. 192, 199-200 (1991), and we must enforce the
laws as written and interpreted, see Marsh & McLennan Cos. v.
United States
, 302 F.3d 1369, 1381 (Fed. Cir. 2002); Philadelphia
& Reading Corp. v. United States
, 944 F.2d 10…