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97 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  2. 86 FR 73976 — Revision of Annual Information Return/Reports
    ERISAFinal Rules (FR)Dec 29, 2021
    …ECURE Act amended ERISA section 103(g) to provide that it applies to plans subject to ERISA section 210(a), and there may be a relatively small number of defined benefit MEPs that are subject to ERISA section 210(a), in the Department's view, it would not be a reasonable reading of the statutory text to conclude that C…
  3. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    nd contribution, made during December 1986, would be deductible in 1986, because that contribution would not be required to be included as part of the VEBA as of its taxable year ending November 30, 1986. Accordingly, petitioner argues, the regulation contradicts the plain language of section 419 and is invalid. Petiti…
  4. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    IRCCourt RulingsJan 20, 1983related by meaning
    sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
  5. REG-121508-18 — Notice of Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Apr 11, 2022
    …m., and published in the issue of the Federal Register for March 28, 2022, 87 F.R. 17225) 1 Section 210 of the Employee Retirement Income Security Act of 1974, Pub. L. 93-406 (88 Stat. 829), as amended (ERISA), also provides rules relating to plans maintained by more than one employer. Similar to section 413(c) of the …
  6. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    least 95 percent of the active participants in the terminated plan who remain as employees of the employer after the termination. Sec. 4980(d)(2)(A)↩. 5. See Estate of Young v. Commissioner, 81 T.C. 879↩ (1983) (holding this Court generally lacks jurisdiction over the sec. 6651(a)(2) addition to tax for failure to pay …
  7. 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
    ….01 Scope limited to issues specified 209 .02 Generally not in employee plans qualification matters 210 .03 Request to Employee Plans Rulings and Agreements for extension of time for making an election or for other relief under § 301.9100-1 of the Procedure and Administration Regulations 210 .04 Issuance of a letter ru…
  8. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  9. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  10. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …rvice in examining the taxpayer’s return 209 .04 May be revoked or modified if found to be in error 210 .05 Letter ruling revoked or modified based on material change in facts applied retroactively 210 .06 Not otherwise generally revoked or modified retroactively 210 .07 Retroactive effect of revocation or modification…
  11. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  12. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    Long-term disability benefits 2,500,000 Union medical benefits 3,210,991 Postretirement benefits Retirees 10,779,650 Active employees 16,133,508 Total 3 $42,125,465 1 Respondent has allowed a deduction for this amount. 2 Respondent has allowed a deduction for this amount. 3 Petitioner’s chief financial officer suggeste…
  13. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …lving multiple offices, fee categories, issues, transactions, or entities 209 .07 Method of payment 210 .08 Transmittal forms 210 .09 Effect of nonpayment or payment of incorrect amount 210 .10 Refunds of user fees 211 .11 Request for reconsideration of user fee 213 SECTION 31. WHAT ARE THE MAILING ADDRESSES FOR REQUES…
  14. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    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…
  15. Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u…
    IRCNoticesApr 6, 2009
    …7,536 Total fair market value at beginning of quarter, including contributions receivable $228,000 $210,200 $221,600 $215,300 $274,436 The fair market value of assets, plan contributions, benefit payments, and other relevant items for the four quarters of 2009 are shown in the table below: Quarter beginning 1/1/2009 4/…
  16. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    must decide whether the Court has jurisdiction to review respondent's whistleblower claim award determination where the claim is based on information the whistleblower provided both before and after the enactment of TRHCA sec. 406, 120 Stat. at 2958.9 ¹° I. Overview of the Court's Jurisdiction and the Whistleblower Pr…
  17. I.R.C. § 72(d)(1)(B)(iii) — Annuities; certain proceeds of endowment and life insurance contracts
    IRCCode / StatuteJan 6, 2025
    …55 but not more than 60 310 More than 60 but not more than 65 260 More than 65 but not more than 70 210 More than 70 160. (d)(1)(B)(iv) (iv) Number of anticipated payments where more than one life If the annuity is payable over the lives of more than 1 individual, the number of anticipated payments shall be determined …
  18. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  19. Treas. Reg. § 1.404(a)-13(c) — Contributions of an employer where deductions are allowable under section 404(a) (1) or (2) and also under section 404(a)(3); application of section 404(a)(7).
    IRCRegulationsMay 18, 2016
    …0 3. Total deductible for year subject to limitation 215 90 140 80 4. Limitation applicable to year 210 175 120 85 5. Amount deductible for year 210 90 120 80 6. Contributions carried over to succeeding years 5 0 20 0 Profit-sharing trust contributions and limitations, deductions, and carryovers under section 404(a)(3)…
  20. 29 C.F.R. § 2520.104b-3(a) — Summary of material modifications to the plan and changes in the information required to be included in the summary plan description.
    ERISARegulationsJan 1, 2017
    …ry, written in a manner calculated to be understood by the average plan participant, not later than 210 days after the close of the plan year in which the modification or change was adopted. This disclosure date is not affected by retroactive application to a prior plan year of an amendment which makes a material modif…