DOL Office of Administrative Law Judges — USDOL, EMPLOYEE BENEFITS SECURITY ADMINISTRATION v. PLAN ADMINISTRATOR, WHITE MOUNTAIN APACHE TRIBE RETIREMENT SAVINGS AND 401(K) PROFIT SHARING PLAN ANNUAL RE… ERISACourt RulingsNov 30, 2016
…ernmental plan” in ERISA to include cer tain Indian Tribal government
plans. Pub. L. No. 109-208, § 806(a)(2)(A), 120 Stat. 780, 1051 (Aug. 17, 2006). To be
eligible for treatment as a governmental plan and exempt from ERISA reporting
IRCCourt RulingsNov 7, 2003
…thout regard to the
amount of tax withheld on a taxpayer's income. Redcay v.
Commissioner
, 12 T.C. 806, 809-810 (1949); sec. 301.6211-1(b),
Proced. & Admin. Regs.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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
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(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsOct 21, 2003
… claimed the standard deduction. On line 16a, Total pensions
and annuities, petitioner reported $42,806 and reported the
entire amount as taxable on line 16b, Taxable amount. On line
30a, Alimony paid, petitioner claimed an adjustment to income of
$17,900 for alimony paid. No other income or adjustments were
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repo…
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsNov 26, 1974related by meaning
970 deducted the amount^ of $996 and $1,276, respectively, representing the sums withheld from petitioner’s wages pursuant to section 8334 of the Act. Respondent in his notice of deficiency disallowed the deduction for amounts withheld under section 8334 of the Act from petitioner’s wages for each of the taxable years …
IRCCourt RulingsJul 5, 2017
… was submitted fully stipulated for decision without trial. M Rule 122.¹
Respondent determined a $3,806 deficiency in petitioner's Federal income
tax for tax year 2012. Petitioner has conceded all adjustments, save for the
inclusion in taxable income of an additional $32,505 in benefits paid by the Local
Governmental E…
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
IRCCourt RulingsApr 19, 2004related by meaning
e language could have
been more precise as to this assumption, when considered in its
entirety, the notice of determination indicates that the Appeals officer was willing to assume that petitioner’s 1989 and 1991 tax
liabilities were discharged in bankruptcy and instead focus
solely on whether the discharge prevents re…
IRCCourt RulingsJun 18, 1997
… payment is made and not the
source of the particular taxpayer's injury. Smelley v. United
States
, 806 F. Supp. 932, 935 (N.D. Ala. 1992), affd. per curiam
3 F.3d 389 (11th Cir. 1993). Thus, if the statute does not
qualify, the fact that the taxpayer's injury was in fact work
related is irrelevant. Id.
Eligibility for…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsMay 22, 2025
… of what is now section 482 was enacted in 1928.
Revenue Act of 1928 , ch. 852, § 45, 45 Stat. 791, 806. Through it,
Congress granted Treasury the authority to reallocate the reported
income and deductions of related businesses “in order to prevent evasion
of taxes or clearly to reflect the income of any such trades or…
IRCCourt RulingsJun 14, 2012related by meaning
(a)
are met. We disagree. Section 491(a) applies only to subtitles A and B,'which
include income taxes and estate and gift taxes. See also Paschall v. 17Petitioners conceded another adjustment to the Yolo return. See supra
note 4.
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Commissioner, 137 T.C. 8, 17 (2011). Respondent determined the excise tax due
unde…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…ces electronically, resulting in roughly 665,458 fewer notices in the first year and on average 605,806 fewer in subsequent years being mailed. since the initial enrollment notice provides an opportunity for RCH/PSN to consolidate two notices into one. This reduction of notices being sent has an associated estimated co…
IRCCourt RulingsSep 23, 2019related by meaning
or the taxing
authority that imposed the levy. Petitioners have not shown that they are eligible
for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a
loan which they used to purchase a home in Vermont in 2013. Petitioners
provided only Form 1099-…
IRCCourt RulingsMay 5, 1998
…Sec. 6651(a)(1); United States v.
Boyle
, 469 U.S. 241, 245 (1985); Davis v. Commissioner
, 81 T.C.
806, 820 (1983), affd. without published opinion 767 F.2d 931
(9th Cir. 1985).
2. Section 6662(a)
Taxpayers are liable for a penalty under section 6662 equal
to 20 percent of the part of the underpayment which is
attribu…
IRCCourt RulingsNov 25, 2002related by meaning
d validity of his Veazie
property-IRA. However, petitioner candidly admitted at trial
that no such written agreement regarding his Veazie property-IRA exists, but that such a designation exists in MHI’s corporate
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16
We do not regard petitioner’s statements regarding the
Veazie property-IRA as credible evidence w…
IRCCourt RulingsNov 12, 1981related by meaning
e deductible, there must be a written instrument governing such account which was extant by the time prescribed for the making of such a contribution. During 1975, Mr. Cobb had only a Keogh account. It was not until December 15, 1976, when he executed the account registration statement with Connecticut General, that he…
IRCCourt RulingsNov 8, 1976
…66.26 10
K. LeBlanc. 44.94 0
J. Veillon. 18.60 0
Total. 1,046.31
Quality Brands' — 1972
D. Hebert. $806.41 15
W. Seaux. 338.89 5
R. Davidson. 80.81 0
R. Allen. 53.88 0
G. Ashy. 59.25 0
J. Stelly. 35.01 0
Total. 1,374.25
Beverage Sales — 1972
J. Deshotel. $1,049.38 15
IRCCourt RulingsJul 24, 1991related by meaning
Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute.
II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …