IRCCourt RulingsNov 28, 2023
…ion from a qualified retirement plan. Respondent has filed a
Motion for Summary Judgment under Rule 121, contending that there
are no disputes of material fact and that he is entitled to judgment as a
matter of law. We agree and accordingly will grant the Motion.
Background
The following facts are based on the parties …
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…ternative Investments
(2013) (available at www.oig.dol.gov/public/reports/oa/2013/09-13-001-12-121.pdf);
U.S. Gov't Accountability Office, GAO-12-665, Private Sector Pensions: Federal Agencies Should Collect Data and Coordinate Oversight of Multiple-employer Plans
(2012) (available at
www.gao.gov/assets/650/648…
IRCCourt RulingsJan 28, 2002★ strong match
…randum.
Discussion
A. Respondent’s Motion for Summary Judgment
Respondent filed a motion under Rule 121(b) seeking summary
judgment upholding the determination in the notice of deficiency.
We may grant summary judgment if there is no genuine issue of
material fact and a decision may be rendered as a matter of law.
Rule…
76 FR 67105 — Cash Balance Plans; Benefit Determinations and Plan Valuations for Statutory Hybrid Plans; Pension Protection Act of 2006 PBGCProposed Rules (FR)Proposed Oct 31, 2011
… part.
(3)
Involuntary termination exception.
If a benefit payment is calculated pursuant to § 4022.121(a)(3)(ii), the benefit will be valued based on the interest crediting rate and the annuity conversion rate in effect under the plan as of the plan's termination date (subject to the rules of §§ 4022.121 through 4022.…
IRCCourt RulingsJan 3, 2011★ strong match
gift tax As Mrs. Cadwell
would be the' hypotlietical' donorain' thé scehario posited by
petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention
sec tion 102 (a) , which exc ludes f rom- gros s income the value of
property acquired by Égift Howeve…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu… IRCRevenue RulingsDec 8, 2003related by meaning
INCOME TAX
Rev. Rul. 2003-122 Rev. Rul. 2003-122
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003.
T.D. 9095 T.D. 9095
REG-136890-02
Final, temporar…
IRCCourt RulingsSep 17, 2026
…trials. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C . 73, 74 (2001). Ordinarily, under
Rule 121(a)(2) the Court may grant summary judgment when there is
no genuine dispute as to any material fact and the movant is entitled to
judgment as a matter of law . Sundstrand Corp. v. Commissioner, 98
T.C. 518, 520 (1992…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021related by meaning
lve the complaint.
Department of the Treasury
Internal Revenue Service
Accordingly, 26 CFR part 54 is amended as follows:
PART 54—PENSION EXCISE TAXES Paragraph 4. The authority citation for part 54 continues to read, in part, as follows:
Authority:
26 U.S.C. 7805, unless otherwise noted.
* * * * *
Par. 5. Section 54.9…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 601(3) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
100.
Medical Expenditure Panel Survey Insurance Component, Agency for Healthcare Researc…
IRCProposed Rules (FR)Proposed May 13, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
186.
13 CFR 121.201 (2011).
Back to Citation
187.
15 U.S.C. 631
et seq.
(2011).
Back to…
IRCCourt RulingsApr 11, 2012related by meaning
nt and
other official explanations of such treaties; court cases; congressional
intent as reflected in committee reports, joint explanatory statements of managers included in conference committee reports, and floor
statements made prior to enactment by one of a lhill's managers;
General Explanations of tax legislation …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…all Business Administration in making this determination, as required by 5 U.S.C. 603(c) and 13 CFR 121.903(c). Memorandum received from the U.S. Small Business Administration, Office of Advocacy on July 10, 2020.
Back to Citation
43.
13 CFR 121.201 (2011).
Back to Citation
44.
15 U.S.C. 631
et seq.
(2011).
Back to C…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
ERISACourt RulingsJan 20, 1998
…7; for a 92 day period (October 19,
1987 to January 1, 1988) at 7% interest yields $3,016.44; for a 121
day period (January 18, 1988 to May 17, 1988) at 6.65% interest
yields $3,763.97; for a 121 day period (May 17, 1988 to September
14, 1988) at 6.75% interest yields $3,820.57; and for a 365 day
period (September 14, …
IRCCourt RulingsDec 18, 2012
… Court disagrees
with this treatment, the respective deficiencies are $108,656, $67,059, $126,860, $121,404, $154,258, and $117,884.
We decide the following issues:4
1. whether petitioners' gross income for the subject years includes
nonemployee compensation of $483,591, $487,873, $536,145, $628,500,
$694,986, and $815…
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…
IRCCourt RulingsJun 29, 1977related by meaning
plied to render the interest part of Mr. Newman’s consideration for the contract, particularly sec. 1.72 — 2(b)(l)(i), Income Tax Regs., which states: Amounts. (l)(i) In general, the amounts to which section 72 applies are any amounts received under the contracts described in paragraph (a)(1) of this section. However, …
IRCCourt RulingsOct 8, 2003
121 T.C. No. 14
UNITED STATES TAX COURT
JIMMY D. WEAVER AND MARLENE M. MORLOC WEAVER,
Petitioners v
. COMMISSIONER OF INTERNAL
REVENUE, Respondent
Docket No. 8262-01. Filed October 8, 2003.
P owned 80-percent interests in an S corporation
(CL) and a C corporation (J). CL is an accrual method,
calendar year taxpayer. J …