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72 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
  2. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  3. Notice 2009-8 — This notice provides interim guidance on recently enacted section 457A of the Code which became effective January 1, 2009. Section 457A generally provides that…
    IRCNoticesJan 26, 2009
    …mpensation plan, the term gross income of the partnership has the same meaning as for purposes of § 702(c) (see also §§ 1.702-1(c) and 1.704-1(b)(1)(vii)). A partnership is a U.S. relevant partnership if it either (i) is required to file a return of partnership income under § 6031 or (ii) determines the distributive sh…
  4. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …ced administrative fee amount finalized in these rules, the Departments estimate that approximately 702,000 disputes [279] would require the initiating party to submit a notice of certified IDR entity selection form a single time. The Departments estimate that it will take an office clerk 30 minutes (at an hourly rate …
  5. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …rtner has sufficient net investment income —is a partner- level affected item determination . See § 702(a)( 7) (requiring a partner to separately account for “ other items of . . . deduction . . . to the extent provided by regulations prescribed by the Secretary ” ); Treas. Reg. § 1.702- 1(a)(8)(iii) (“Each partner sha…
  6. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …s estimate the prevented fatalities from all causes arising from OUD treatment to be: 2,024−1,322 = 702 prevented fatalities. Back to Citation 316.  This estimate is calculated as: the value of a statistical life of $13,200,000 × 702 prevented fatalities = $9,269,545,489. Back to Citation 317.
  7. Treas. Reg. § 1.404(e)-1A(f) — Contributions on behalf of a self-employed individual to or under a qualified pension, annuity, or profit-sharing plan.
    IRCRegulationsMar 14, 2019
    …) Partner's distributive share of contributions and deductions. (f)(1) (1) For purposes of sections 702(a)(8) and 704 in the case of a defined contribution plan, a partner's distributive share of contributions on behalf of self-employed individuals under such a plan is the contribution made on his behalf, and his distr…
  8. 101 T.C. 518; 101 T.C. No. 34 — Janpol v. Commissioner
    IRCCourt RulingsDec 7, 1993related by meaning
    situation should not be permitted to continue and has adopted measures designed to reduce substantially the potentialities for abuse in this regard.- The Committee noted that the new rules (sec. 4975) would make enforcement more practical and better ensure the integrity of benefit plans. The structure of sec. 4975 ref…
  9. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    … As of January 1, 2016, the present value of the remaining waiver amortization installments is $259,702, which is determined by discounting the remaining four waiver amortization installments of $70,000 each to January 1, 2016, using the first segment rate of 5.26%. See paragraph (c)(2)(ii) of this section.(iii) A $440…
  10. 29 C.F.R. § 2510.3-1(l)(5) — Employee welfare benefit plan.
    ERISARegulationsAug 19, 2019
    …idual health insurance coverage, the notice must satisfy the notice requirement set forth in § 2590.702-2(c)(6) of this chapter. A QSEHRA or an HRA not subject to the notice requirement set forth in § 2590.702-2(c)(6) of this chapter may use the following language to satisfy this condition: “The individual health insur…
  11. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    ed as a result. “Good intentions and a pure heart are no defense” to liability under section 4975(a). Leib v. Commissioner, 88 T.C. 1474, 1481 (1987). ERISA section 406, which is contained in the labor title and which parallels section 4975(c), defines prohibited transactions in which plan fiduciaries are not to engage…
  12. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    ing, we directed petitioner to submit a response to respondent's supplement and offered respondent the opportunity to reply to petitioner's response . On June 15, 2007, petitioner's response to respondent's supplement was filed . On July 12, 2007, respondent replied . Discussio n I . Section 6015(e ) Section 6015(e) ge…
  13. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016related by meaning
    sult in higher administrative costs." H.R. Rept. No. 109-232 (Part 1), at 68 (2005).¹² Respondent acknowledges that section 4975(d)(23) can apply to a prohibited transaction between an IRA and its owner (or beneficiary). Respondent argues, however, that the effective date of the section makes it inapplicable here in th…
  14. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    sonable compensation and therefore not deductible under section 162 (and thereby section 404), the 10% section 4972 excise tax applies to that extent. V. Section 6651(a)(1) and (2) Additions to Tax Respondent contends that the corporation is liable for section 6651(a)(1) failure to file additions to tax of $10,050.95 a…
  15. 111 T.C. No. 15 — John F. Romann v. Commissioner
    IRCCourt RulingsNov 4, 1998related by meaning
    laration shall have the force and effect of a decision of the Tax Court and shall be reviewable as such. For purposes of this section, a determination with respect to a continuing qualification includes any revocation of or other change in a qualification. (b) Limitations.-- (1) Petitioner.--A pleading may be filed und…
  16. 106 T.C. No. 20 — Alfred E. Gallade v. Commissioner
    IRCCourt RulingsMay 28, 1996
    …’s terms and operations must meet the statutory requirements.” Fazi v. Commissioner , 102 T.C. 695, 702 (1994); see Ludden v. Commissioner , 620 F.2d 700, 702 (9th Cir. 1980), affg. 68 T.C. 826 (1977); see also Guidry v. Sheet Metal Workers Natl. Pension Fund
  17. T.C. Memo. 2011-62 — Christy & Swan Profit Sharing Plan v. Commissioner
    IRCCourt RulingsMar 15, 2011related by meaning
    ner, T.C. Memo. 2005-70. Section 401(a) sets forth the requirements that must be met by a trust forming part of a profit-sharing plan in order for the trust to be eligible for favorable -tax treatment. Section 7476(a) confers jurisdiction on this Court to issue declaratory judgments as to the initial and continuing qua…
  18. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    …965_ 38,039 38,039.00 1966_ 53,246 53,246.00 1967_ 62,450 62,450.00 1968_ 72,735 72,735.00 1969_ 75,702 75,702.00 1970: 1/1 -11/23_ 81,473 11/23 — 11/30 _ $923.08 $16,469.88 102,558.28 12/1 -12/31_ 3,692.32 1971_ 48,000.16 17,023.82 65,023.98 1972_ 48,223.24 16,003.16 64,226.40 1973_ 48,000.16 16,900.24 64,900.40 1974_…
  19. T.C. Summary Opinion 2014-17 — Rebecca Smackey Hurd v. Commissioner
    IRCCourt RulingsFeb 25, 2014related by meaning
    19(a). The deduction may not exceed the lesser of: (1) the deductible amount, which was generally $5,000 for the 2008 tax year; or (2) an amount equal to the compensation includible in the taxpayer's gross income for such taxable year. Sec. 219(b)(1), (5)(A). However, the deductible amount allowed under section 219(a) …
  20. 37 T.C. 817 — Wasatch Chemical Co. v. Commissioner
    IRCCourt RulingsJan 24, 1962
    …made its contribution for 1956 by delivering to the trust its promissory note in the amount of $36,-702.93. This note was also unsecured, bore interest at the rate of 6 percent per annum, and was to mature on March 1, 1962. This note was discharged on December 8, 1958. In filing its Federal corporation income tax retur…