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77 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ble. Zmuda v. Commissioner , 79 T.C. 714, 727 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). In this instance, petitioner readily admits that A Atlantic is presently holding his property, and that there is a - 9 - 7 For the purposes of sec. 72(t), the term "employee" also refers to participants in individual retirement a…
  2. 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…
  3. T.D. 9325 — Final regulations under section 401 of the Code provide rules permitting in-service distributions to be made to a participant from a pension plan upon the part…
    IRCTreasury DecisionsJun 11, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-37 Rev. Rul. 2007-37 Cancellation of distributorship agreement. This ruling holds that the cancellation of an agreement to distribute a manufacturer’s products may be a sale or exchange of property. The gain may be capital gain or treated as capital gain and may be subject to recapture. REG-14…
  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. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    s any proceedings before us. The mere fact that petitioners are defending the position that was advertised to them in connection with their investment in the subject VEBA’s is insufficient grounds to penalize each petitioner under the facts herein. Petitioners are not directly responsible for most of the actions listed…
  7. 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.
  8. 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…
  9. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
  10. 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…
  11. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    . 634, 648 (1994), affd. without published opinion 89 F.3d 856 (11th Cir. 1996). Section 402(b) (2) provides "the amount actually distributed" or made available to a distributee by a nonexempt employee trust must be included in the distributee's gross income pursuant to the annuity rules of section 72. See also sec. 1.…
  12. 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…
  13. 102 T.C. 695; 102 T.C. No. 31 — Fazi v. Commissioner
    IRCCourt RulingsMay 19, 1994related by meaning
    nth Circuit are binding in the Eleventh Circuit. See, however, Boggs v. Commissioner, 784 F.2d 1166, 1171-1172 (4th Cir. 1986) (Hall, J., dissenting). Sec. 402(a)(2) limited capital gains treatment of “lump sum distributions” where the distribution is made from an employee trust “which is exempt from tax under section …
  14. 63 T.C. 621 — Packard v. Commissioner
    IRCCourt RulingsMar 11, 1975related by meaning
    al right to decrease or altogether avoid such taxes by means which the law permits. Gregory v. Helvering, supra; Daniel D. Palmer, 62 T.C. 684 (1974). Respondent asserts that the result and reasoning of Rev. Rul. 68-303, 1968-1 C.B. 165, should control this case. In Rev. Rul. 68-303, a partnership entered into a contra…
  15. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  16. 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…
  17. 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
  18. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
  19. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…
  20. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    n fund. Accordingly, because petitioner constructively received the IRA distribuitions in 2009, they are includable in his gross income for that year. Petitioner lastly argues that the 2008 garnishment order violated the Consumer C edit Protection Act as well as the Mandatory Victims Restitution Act. Petitioner request…