PBGCCode / StatuteJan 6, 2025related by meaning
(d)(2)(E) (E) each employer who has an obligation to contribute, within the meaning of section 1392(a) of this title, under a multiemployer plan, and
(d)(2)(F) (F) each employee organization which, for purposes of collective bargaining, represents plan participants employed by an employer described in subparagraph (C),…
ERISACode / StatuteJan 6, 2025related by meaning
(n) (n) Pension-linked emergency savings accounts Nothing in this section shall preclude the Secretary from providing, by regulations or otherwise, simplified reporting procedures or requirements regarding such a pension-linked emergency savings account.
ERISACode / StatuteJan 6, 2017related by meaning
(a)(1)(C) (C) has a 1-year break in service (as defined in section 1053(b)(3)(A) of this title).
(a)(2) (2) If more than one employer adopts a plan, each such employer shall furnish to the plan administrator the information necessary for the administrator to maintain the records, and make the reports, required by parag…
ERISACode / StatuteJan 6, 2017related by meaning
(a)(4)(B) (B) in the case of a qualifying event described in paragraph (3) or (5) of section 1163 of this title where the covered employee notifies the administrator under paragraph (3), any qualified beneficiary with respect to such event,
IRCCourt RulingsJul 13, 2010
…ayer must execute
the return under penalties . of . perjury . Beard v . Commissioner , 82
T .C . . .766, 777 (1984), affd . 793 F .2d 139 (6th Cir . 1986) .- The
2000, 2001, and 2002 Forms 1040 petitioners sent to respondent
omitted most of petitioners' taxable income, as discussed above .
We conclude that petitioners'…
IRCCourt RulingsFeb 9, 2023
…de, for the first time, a definition of the very term
that the regulation interpreted. Id. a t 764, 766. Accordingly, the reasons for amending
the regulation were to some extent self-evident: There had been a statutory reset. As
described in Part II below, the addition of the second sentence to section 482 is not
analo…
IRCCourt RulingsJun 4, 1984related by meaning
nd holding of employer securities and employer real property by certain plans. Section 408, ERISA, sets forth exemptions from prohibited transactions. Violations of the labor provisions contained in ERISA may result in any number of sanctions against the fiduciary. For example, under section 409(a), ERISA, a fiduciary …
PBGCCode / StatuteJan 6, 2017related by meaning
(f)(5) (5) The liability of the party furnishing a bond or escrow under this subsection shall be reduced, upon the payment of the bond or escrow to the plan, by the amount thereof.
IRCCourt RulingsMay 31, 1989
…ns or inaccuracies are such as to make amendment necessary.
See also Beard v. Commissioner, 82 T.C. 766 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986); W.K. Buckley, Inc. v. Commissioner, 158 F.2d 158, 161 (2d Cir. 1946).
IRCCourt RulingsAug 25, 1997
…7
- 29 -
17
(...continued)
Commissioner
, 931 F.2d 1044 (5th Cir. 1991); Keasler v. United
States
, 766 F.2d 1227 (8th Cir. 1985).
After the Court of Appeals decided Adler v. Commissioner
,
supra
, respondent had a 45-day period to petition the Court of
Appeals for rehearing or rehearing en banc, see Fed. R. App. P.
35…
PBGCCode / StatuteJan 6, 2017related by meaning
(d) (d) Notwithstanding any other provision of this subchapter, guaranteed benefits payable by the corporation pursuant to its discretionary authority under this section shall continue to be paid at the level guaranteed under section 1322 of this title, without regard to any limitation on payment under subparagraph (C)…
ERISACode / StatuteJan 6, 2025related by meaning
(b)(20)(E)(iii)(II) (II) to restore to the plan or affected account any profits made through the use of assets of the plan.
(b)(21) (21) The provision of a de minimis financial incentive described in section 401(k)(4)(A) or section 403(b)(12)(A) of title 26.
IRCCourt RulingsOct 9, 1997
…urrent active employees not covered by a collectively bargained
agreement, were $10,732,153 and $23,766,492, respectively.
Pursuant to the VEBA Trust agreement, the VEBA Trust's
assets, including the December 29, 1987, contribution, additional
contributions made during 1988, and the trust's investment
earnings, were us…
IRCCourt RulingsFeb 9, 1998
…id return,
developed from Supreme Court precedent, are set forth in Beard v.
Commissioner
, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th
Cir. 1986) as follows:
First, there must be sufficient data to calculate tax
liability; second, the document must purport to be a
return; third, there must be an honest and reason…
IRCCourt RulingsMar 24, 1980
…3,674.40 815,071.65 943,367.46 1,355,989 990,796
Profit-sharing 72,689.89 120,383.34 139,472,13 200,766 146,227
Total 566,364.29 935,454.99 1,082,839.59 1,556,755 1,137,023
Donald J. Carter
Salary $2,400.00 $2,400.00 $2,400.00 $2,400 $2,400
Commission 359,641.55 590,161.20 854,006.78 1,075,478 987,196
Bonus 36,204.45 5…
IRCCourt RulingsAug 6, 1997
…he Commissioner need
only provide a minimal amount of evidence. Williams v.
Commissioner
, supra
at 766; Weimerskirch v. Commissioner
, 596
- 6 -
F.2d 358, 361 (9th Cir. 1979), revg. 67 T.C. 672 (1977). If the
Commissioner fails to provide sufficient evidence, the deficiency
determination is arbitrary, and the Commissi…
IRCCourt RulingsDec 8, 1987
…, the taxpayer must execute the document under penalties of perjury. Beard v. Commissioner, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th Cir. 1986); see also Florsheim Bros. Drygoods Co. v. United States, 280 U.S. 453 (1930).
IRCCourt RulingsNov 23, 2016
…2015-104, at *29-*30, aff'd, 649
F. App'x 299 (4th Cir. 2016).
2°See Beard v. Commissioner, 82 T.C. 766, 781 (1984) (noting that taxpayer
admitted in his brief that he knew Court had rejected arguments similar to his as
(continued...)
- 11 -
[*11] "contrary to established law and unsupported by a reasoned, colorable
ar…
ERISACode / StatuteJan 6, 2017related by meaning
(a)(7) (7) an individual retirement account or annuity as described in section 408(a) of title 26, or a retirement bond described in section 409 of title 26 (as effective for obligations issued before January 1, 1984);
(a)(8) (8) an individual account plan (other than a money purchase plan) and a defined benefit plan t…
IRCCourt RulingsDec 17, 1996
…ment constitutes a "return" for purposes of section
6651(a)(1). See Beard v. Commissioner
, 82 T.C. 766, 777 (1984),
affd. per curiam 793 F.2d 139 (6th Cir. 1986). For example,
there is no evidence here to show that there was "an honest and
-6reasonable attempt to satisfy the requirements of the tax law".
Id.
According…