Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 1975-341 (not yet in the library — opens the official source)
67 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
  2. 81 FR 21208 — Amendments to Class Exemptions 75-1, 77-4, 80-83 and 83-1
    ERISAFinal Rules (FR)Apr 8, 2016
    …vestment advice” to an employee benefit plan within the meaning of ERISA section 3(21)(A)(ii) (the “1975 ( printed page 21210) regulation”).[5] The 1975 regulation narrowed the scope of the statutory definition of fiduciary investment advice by creating a five-part test for fiduciary advice. Under the 1975 regulation, …
  3. 81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co…
    ERISAFinal Rules (FR)Apr 8, 2016
    …ry standards, nor accountable under ERISA or the Code for imprudent, disloyal, or biased advice. In 1975, the Department issued a regulation, at 29 CFR 2510.3-21(c), defining the circumstances under which a person is treated as providing “investment advice” to an employee benefit plan within the meaning of section ERIS…
  4. 81 FR 21089 — Class Exemption for Principal Transactions in Certain Assets Between Investment Advice Fiduciaries and Employee Benefit Plans and IRAs
    ERISAFinal Rules (FR)Apr 8, 2016
    …stment advice” to an employee benefit plan within the meaning of section 3(21)(A)(ii) of ERISA (the 1975 regulation).[6] The 1975 regulation narrowed the scope of the statutory definition of fiduciary investment advice by creating a five-part test for fiduciary advice. Under the 1975 regulation, for advice to constitut…
  5. 69 T.C. 750 — Orzechowski v. Commissioner
    IRCCourt RulingsFeb 22, 1978
    …an and the retirement savings deduction. * * * [H. Rept. 93-807 at 364.] Although toward the end of 1975 the petitioner learned that his employment with Otis would probably be terminated, and although his employment was in fact terminated in January 1976, he remained an employee of Otis throughout the year 1975. The Ot…
  6. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985
    …ted transaction subject to section 4975. Respondent concluded that the loans made before January 1, 1975, the general effective date of section 4975, were subject to the excise taxes because the loans remained outstanding on that date. Petitioner does not deny that it is a "disqualified person” as defined in section 49…
  7. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  8. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  9. IRCCourt RulingsAug 3, 1979
    …. Martens (hereinafter sometimes collectively referred to as the petitioner-employees) were, during 1975, permanent employees of Industrial Nucleon-ics Corp. (hereinafter referred to as Nucleonics). During 1975, all of the petitioner-employees were active participants in the Employee Pension Plan of Nucleonics (hereina…
  10. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  11. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  12. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
    IRCCourt RulingsMay 31, 1989related by meaning
    nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
  13. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
  14. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
  15. 71 T.C. 332 — Brownholtz v. Commissioner
    IRCCourt RulingsDec 4, 1978related by meaning
    … 28), long before promulgation of the challenged paragraph (sec. 1.72 — 15(i), Income Tax Regs.) in 1975 (T.D. 7352,1975-1 C.B. 34). Petitioner’s attack on the validity of section 1.72-15(i), Income Tax Regs., is misguided. Without the “special rule” provided by paragraph (i), the preexisting “general rule” would contr…
  16. 79 FR 58720 — Electronic Filing of Notices for Apprenticeship and Training Plans and Statements for Pension Plans for Certain Select Employees
    ERISAProposed Rules (FR)Proposed Sep 30, 2014
    … Benefits Security Administration, U.S. Department of Labor. Footnotes 1.  See 40 FR 24647 (June 9, 1975); 40 FR 34529, 34530 (August 15, 1975); and 45 FR 34528, 34529 FN 10 (March 11, 1980). Back to Citation 2.  See 40 FR 24647, 24648 (June 9, 1975) and 40 FR 34530 (August 15, 1975). Back to Citation 3.
  17. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    …he list of specific exceptions to tax set forth in section 72(t)(2). Swihart v. Commissioner , T.C. Memo. 1998-407. Moreover, unlike petitioners in the present case, the taxpayers in Larotonda never - 8 - received the funds and had no opportunity to avoid the 10-percent premature distribution penalty under former secti…
  18. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995related by meaning
    …r discovery until the case was recalled for trial at a special session held 20 5 Petitioner filed a Memo to the Court on May 23, 1994, requesting that the Court order respondent to produce and turn over to petitioner documents relating to the examination of petitioners' returns. We do not recognize this Memo as a forma…
  19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  20. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…