85 FR 54288 — Registration Requirements for Pooled Plan Providers ERISAProposed Rules (FR)Proposed Sep 1, 2020
…providers report pooled employer plans beginning operation, 453 pooled plan providers * 0.50 hour = 227 hours. 227 hours * $165.63 = $37,598 3,233 * 0.06 = 453 pooled plan providers report pooled employer plans ending operation, 194 pooled plan providers * 0.50 hour = 977 hours. 97 hours * $165.63 = $16,060.
Back to Ci…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
….01 Scope limited to issues specified
226
.02 Generally not in employee plans qualification matters
227 .03 Request to Employee Plans Rulings and Agreements for extension of time for making an election or for other relief under § 301.9100-1.
227
.04 Issuance of a letter ruling before the issuance of a regulation or oth…
IRCCourt RulingsFeb 24, 2014related by meaning
articipants' accounts.
Discussion
In this declaratory judgment proceeding we review respondent's
determination that the plan was not qualified.
- 10 - [*10] Section 7476(a) authorizes this Court to make a declaration with respect to
the initial or continuing qualification of certain retirement plans when the
limitation…
110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner IRCCourt RulingsApr 27, 1998related by meaning
w why the statute as
enacted contains language different from that in the House and
- 10 -
1
We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize
this Court to grant a declaratory judgment include secs. 6234,
7428, 7477, 7478, and 7479.
2
Sec. 7503 a…
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)…
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
IRCCourt RulingsJun 11, 1996
…rican Bank distributed and petitioner received the
account balance of petitioner's IRA's, i.e., $97,227.74, on or
about November 6, 1990.
Distribution of the Fidelity IRA
Petitioners were accustomed to dealing with Fidelity by
telephone. On August 14, 1990, petitioner Richard Childs
telephoned Fidelity and requested th…
IRCCourt RulingsAug 31, 1978related by meaning
ioner for the purpose of computing its depreciation deductions.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found. The petitioner in docket No. 8683-74 is 212 Corporation (212 Corp.), which had its principal place of business in Erie, Pa., at the time it filed its petition in this ca…
IRCCourt RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…ong test for determining whether to afford an agency
pronouncement Chevron deference . Id . a't 226-227 ("We hold that
administrative implementation of a particular statutory provision
qualifies for Chevron deference when it appears that Congress
delegated authority to the agency generally to make rules
carrying the fo…
IRCCourt RulingsOct 19, 2010related by meaning
tter of local law and a
State court's determination with regards to such assignment is
not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of
Bosch, 387 U.S. 456, 465 (1967), the Court held that where the
Federal estate tax liability turns upon the chara…
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…
IRCCourt RulingsNov 26, 1979related by meaning
for us to glean from congressional silence what would be a significant departure from much case law. Respondent’s inference, rather, is more probable. As we have found that petitioners were not separated from the service of their employer, we need not consider respondent’s other contention that the distributions petiti…
PLR 201103002 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJan 21, 2011
…nsation that can be
deferred under private plans." (H.R. Report No. 95-1445 at 53 and 59, 1978-3 CB 227
and 233).
This indicates that a significant Congressional concern when it enacted section 457 was
limiting the revenue loss that occurs when em ployees defer compensation that their tax -
exempt employer is unable to…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
IRCCourt RulingsOct 12, 1978related by meaning
other than that presented before the Internal Revenue Service and contained in the administrative record as so defined. * * *
See also Rule 210(c)(4). Here, the petitioner timely filed his comment letter with the District Director in which he raised four specific "matters." As to such matters, he exhausted his administ…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
IRCCourt RulingsMay 23, 2011
…ates indicated on his monthly invoices to
the BCG.
- 18 -
questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th
Cir. 1955), affg. a Memorandum Opinion of this Court; Weiss v.
Commissioner, 221 F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo.
1954-51; Schroeder v. Commissioner, T.C. Memo. 1986-467.
The Court i…
IRCCourt RulingsMar 5, 2018related by meaning
1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171
(1931)), aKg T.C. Memo. 1982-209.
With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed
below, we reject petitioners' broadest argument--that the substance doctrines have
no…