PBGCFinal Rules (FR)Jun 6, 2024
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
§ 4041.49
[Amended]
8. Amend § 4041.49 in paragraph (b)(1)(ii) by removing “§§ 4044.41
( printed page 48300)
through 4044.57” and adding in its place “§§ 4044.41 through 4044.58”.
PART 4041A—TERMINATION OF MULTIEMP…
IRCCourt RulingsDec 5, 2007related by meaning
part that the Court hold an
evidentiary hearing so that respondent could question Mr .
Carpenter as to his actions connected with this proceeding and the subject matter thereof . The Court granted respondent's
request . The Court ultimately denied petitioners' motion as
supplemented .
- 57 -
Associates, P .A . v . Com…
IRCCourt RulingsSep 24, 2007related by meaning
)(2) addition to tax . The sec .
6651(a)(2) addition to tax was listed only in the Form 4549,
Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that
respondent raised the sec . 6651(a)(2) addition to tax in his
answer, albeit while misciting that sectio…
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…
IRCCourt RulingsJul 24, 1989related by meaning
eceiving from the IRS only the acknowledgment of the applications, two phone calls from Ms. Islas and the final adverse determination letters.
OPINION Section 7476 creates a judicial remedy for taxpayers seeking determinations of qualification of retirement plans under section 401(a), which latter section lists the cha…
IRCCourt RulingsNov 14, 1996
…ommissioner
, 98 T.C.
l41, 149 (1992); Zinniel v. Commissioner
, 89 T.C. 357 (1987), affd. 883 F.2d 1350 (7th Cir. 1989).
Section 404(a) covers deductions in respect of contributions
to pension trusts, employees' annuities, stock bonus and profitsharing trusts, foreign trusts, and other plans "deferring the
receipt of …
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
on 6662A.
After the parties’ filing of Stipulations of Settled Issues,
2
the
issues remaining for consideration are (1) the fair market value of the
1 Unless otherwise indicated, statutory references are to the Internal Revenue
Code, Title 26 U.S.C. (Code), in effect at all relevant times, regulation references are
to …
84 FR 30666 — Miscellaneous Corrections, Clarifications, and Improvements PBGCProposed Rules (FR)Proposed Jun 27, 2019
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
14. Revise § 4041.29 to read as follows:
§ 4041.29
Post-distribution certification.
(a)
Filing requirement.
The plan administrator must either—
PBGCCode / StatuteJan 6, 2017
… whether participants and beneficiaries have received their benefit commitments and whether section 1350(a) of this title has been satisfied. Each audit shall include a statistically significant number of participants and beneficiaries.
PBGCProposed Rules (FR)Proposed Sep 20, 2016
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
9. In § 4041.28:
a. Paragraph (a)(3) is added;
b. Paragraph (c)(5) is amended by removing “part 4050” and adding in its place “subpart A of part 4050 of this chapter”.
The addition reads as follows:
§ 4041.28
Close…
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…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsNov 25, 2008related by meaning
C, sec . 408 ,
SERVED NOV 2 5 2088
I
- 2 -
120 Stat . 3061 (TRHCA sec . 408) . TRHCA sec . 408(a) and
(c), 120 Stat . 3061, 3062, amended former sec . 6015(e)(1), I .R .C ., to clarify that the Court has
jurisdiction to decide a nondeficiency sec . 6015(f)
case involving the taxpayer's "liability for taxes
arising or r…
IRCCourt RulingsOct 29, 2013related by meaning
ed CST, an entity owned by his IRA, to enter into a lease agreement
with CDJ, an entity owned by both petitioners and their children in tax year 2006. The notice of deficiency also reflected respondent's determination that, for
the year in which the prohibited transaction occurred petitioners are liable for the
additio…
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
the treaty jurisdiction.
VI. Purpose of Proposed Regulation
On March 3, 2022, the Sixth Circuit issued an order in
Mann Construction
v.
United States, 27 F.4th 1138, 1147 (6th Cir. 2022), holding that Notice 2007-83, 2007-2 C.B. 960, which identified certain trust arrangements claiming to be welfare benefit funds and i…
PBGCCode / StatuteJan 6, 2017
…efit liabilities under the plan. A transfer of assets to the corporation in accordance with section 1350 of this title on behalf of a missing participant shall satisfy this subparagraph with respect to such participant.
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 …
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
14. Amend § 4041.21 by adding paragraph (b)(2)(v) to read as follows:
§ 4041.21
Requirements for a standard termination.
* * * * *
(b) * * *
(2) * * *
(v) In any case in which the majority owner has an option to ac…
IRCCourt RulingsMar 5, 2018related by meaning
r I.R.C. sec. 4973.
He] : On the facts presented, Ps and not their Roth IRAs were
the owners, for Federal tax purposes, of the FSC stock; in substance the FSC dividends were income to Ps, who contributed the funds to
their Roth IRAs. Summa Holdings, Inc. v. Commissioner, 848 F.3d
779 (6th Cir. 2017), rev'g T.C. Memo. 2…