IRCRegulationsOct 7, 2021
…ms and appeals process. Specifically, in addition to complying with the requirements of 29 CFR 2560.503-1(h)(2)— (1) The plan or issuer must provide the claimant, free of charge, with any new or additional evidence considered, relied upon, or generated by the plan or issuer (or at the direction of the plan or issuer) i…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…9 U.S.C. 1132, 1135, and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Section 2560.503-1 also issued under 29 U.S.C. 1133. Section 2560.502c-7 also issued under 29 U.S.C. 1132(c)(7). Section 2560.502c-4 also issued under 29 U.S.C. 1132(c)(4). Section 2560.502c-8 also issued under 29 U.S.C. 1132(c)(8).
…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…9 U.S.C. 1132, 1135, and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Section 2560.503-1 also issued under 29 U.S.C. 1133. Section 2560.502c-7 also issued under 29 U.S.C. 1132(c)(7). Section 2560.502c-4 also issued under 29 U.S.C. 1132(c)(4). Section 2560.502c-8 also issued under 29 U.S.C. 1132(c)(8).
…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
ar 1954 under the provisions of section 404(a)(5), and section 1.404(a)-12, Income Tax Regs.
On brief, petitioner states the “Issue To Be Decided” as— Where the petitioner obligated itself to pay to the widow of its deceased President an amount equivalent to the monthly salary of the deceased President for a period of …
IRCCourt RulingsAug 16, 2017related by meaning
en of proving that
those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290
U.S. I11, 115 (1933).
I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a
qualified retirement plan equal to 10% of the portion of the amount that is
includable in gros…
IRCCourt RulingsMar 31, 2005
…the distribution; i.e.,
$51,497. This amount consists of the whole distribution of
$77,000 less $25,503. The amount of $25,503 is attributable to
Mr. Seidel as beneficiary and distributee, and it consists of
- 19 -
$15,503, which is one-half of the two joint liabilities paid off
by the proceeds of the CWSC 401(k) distr…
IRCCourt RulingsOct 25, 1977related by meaning
…nt’s alternative arguments that the loan to Mr. Feroleto was a prohibited transaction under section 503.
IRCCourt RulingsApr 19, 2005
… distribution; i.e.,
$51,497. See Seidel v. Commissioner
, T.C. Memo. 2005-67. The remainder of $25,503 is attributable to petitioner as beneficiary
and distributee, and it consists of $15,503, which is one-half of
the two joint liabilities paid off by the proceeds of the CWSC
401(k) distribution, plus the $10,000 chec…
IRCCourt RulingsOct 4, 1979related by meaning
be based on principles similar to the principles which apply in the case of subsection (b). [Emphasis added.]
SEC. 414. DEFINITIONS AND SPECIAL RULES. (b) Employees of Controlled Group of Corporations. — For purposes of sections 401,408(k), 410, 411 and 415, all employees of all corporations which are members of a cont…
IRCCourt RulingsMay 19, 2011related by meaning
cy here was transferred to
Mr. Lowe by way of a distribution from a nonexempt employee
trust, a situation specifically contemplated by section 402(b). Section 83, which addresses the taxation of property transferred
in connection with services, is thus general when compared with
the specific application of section 402(…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…dited notification of benefit determinations involving urgent care. The requirements of 29 CFR 2560.503-1(f)(2)(i) (which generally provide, among other things, in the case of urgent care claims for notification of the plan's benefit determination (whether adverse or not) as soon as possible, taking into account the me…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
PLR 200005001 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsFeb 4, 2000
as an
administrative tax claim pursuant to BC §503(b)(1)(B)(i).
ISSUE 3
If the court were to find that the IRC §4980 liability is a penalty, we do not recommend that your office argue that the penalty in this case is the type of penalty
covered under BC §503(b)(1)(C). Therefore, if the IRC §4980 liability is a penalty,…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
78 FR 68240 — Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008; Technical Amendment to External Review for Multi-… IRCFinal Rules (FR)Nov 13, 2013
…son, generally are considered plan participants for this purpose.
Back to Citation
24.
29 CFR 2560.503-1. See also26 CFR 54.9815-2719T(b)(2)(i), 29 CFR 2590.715-2719(b)(2)(i), and 45 CFR 147.136(b)(2)(i), requiring non-grandfathered plans and issuers to incorporate the internal claims and appeals processes set forth i…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
DOL Info. Ltr. 02-27-2019 — Application of the authorized representative provisions of 29 CFR 2560.503-1, regarding the designation of an authorized representative for the initial claim f… ERISADOL Information Letters
… in section 11 of ERISA Procedure 76-1. The Department’s claims procedure regulation at 29 CFR 2560.503-1 sets forth minimum requirements for employee benefit plan claims procedures under ERISA. Subparagraph (b)(4) of the regulation expressly gives participants and beneficiaries the right to appoint authorized represen…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsJan 28, 2014related by meaning
…st comply with specific requirements for
any deductions claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84
(1992); New Colonial Ice Co. v. Helvering, 292 U.S. at 440. Taxpayers must also
maintain adequate records to substantiate the amounts of any credits and
deductions. Sec. 6001; sec. 1.6001-1(a), Income Tax…