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82 documents · 0.31sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  2. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
  3. Treas. Reg. § 1.219-2(h) — Definition of active participant.
    IRCRegulationsApr 14, 2016
    … he is a participant in the plan. However, B completes less than 1,000 hours of service in 1980 and 1981. Although B is not accruing any benefits under the plan in 1980 and 1981, he is an active participant under section 219(b)(2) because he is a participant in the plan. Thus, B cannot make deductible contributions to …
  4. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    …to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining whether a partial termination has occurr…
  5. Treas. Reg. § 1.410(a)-5(c)(3)(ii) — Year of service; break in service.
    IRCRegulationsSep 9, 2016
    …December 31, 1980, and incurs a 1-year break in service for the 12-month period ending December 31, 1981. The plan does not contain the provisions permitted by section 410(a)(5)(B) (relating to 3-year 100 percent vesting) and section 410(a)(5)(D) (relating to nonvested participants). Thereafter, he does not complete a …
  6. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  7. T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.…
    IRCTreasury DecisionsApr 30, 2007
    Comprehensive regulations regarding section 415 were last issued in 1981. See T.D. 7748, 1981-1 C.B. 259, published in the Federal Register on January 7, 1981 (46 FR 1687). Since then, changes to section 415 have been made in the Economic Recovery Tax Act of 1981, Public Law 97-34 (95 Stat. 320) (ERTA), the Tax Equity …
  8. PLR 201848011 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsNov 30, 2018
    …contributions. Revenue Ruling 2006-43, 2006-35 I.R.B. 329, amplifying and modifying Rev. Rul. 81-35 1981-5 I.R.B. 11, 1981-1 C.B. 255, Rev. Rul. 81-36 1981-5 I.R.B. 12, 1981-1 C.B. 255, and Rev. Rul. 87-10 1987-5 I.R.B. 4, 1987-1 C.B. 136, des cribes the actions required for a state or political subdivision of a state,…
  9. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  10. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    … the computation to start on the same date the COLA's were started under the EAJA; i.e., October 1, 1981. Id. at 23. Citing Lawrence v. Commissioner , 27 T.C. 713 (1957), revd. on other grounds 258 F.2d 562 (9th Cir. 1958), we stated that we would continue to use 1981 as the correct year for making the COLA calculation…
  11. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
  12. 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…
  13. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  14. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  15. T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner
    IRCCourt RulingsJul 29, 1997
    …edent's adjusted gross estate. ERTA eliminated this limitation for persons dying after December 31, 1981. The intent of Congress in repealing the marital deduction quantitative limits was to treat a husband and wife as one economic unit and to allow unlimited tax-free transfers within that unit. S. Rept. 97-144, at 127…
  16. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  17. 76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner
    IRCCourt RulingsMar 17, 1981
    …e same rules governing ESOPs with respect to cash and stock distributions. S. Rept. 96-1036 (1980), 1981-6 I.R.B. 41; H. Rept. 96-1278 (1980), 1981-6 I.R.B. 28. In sec. 141, Revenue Act of 1978, Pub. L. 95-600, 92 Stat. 2763, Congress enacted sec. 409A(h) which permitted distribution of property other than employer sto…
  18. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
  19. PBGCPBGC Opinion LettersMay 20, 1998
    …of an owner. See, e.g., PBGC Opini on Let ter s No. 83-16 (July 12, 1983), No . 81-40 (Decem ber 9, 1981), N o. 81-37 (No vember 16, 19 81), No. 81-31 ( Septembe r 22, 1981), No. 81-30 (Sep temb er 22 , 1981), No. 81-13 ( May 13, 1981) , No. 79- 6, (Apr il 10, 1979), N o. 78-25 (Octob er 31, 1978), N o. 77-152 (July 13…
  20. 81 FR 8832 — Regulations Governing Organization of the Joint Board for the Enrollment of Actuaries
    Joint BoardFinal Rules (FR)Feb 23, 2016
    …s, and the Secretary is to be elected from among the Labor Department representatives. On April 27, 1981, the Secretaries of Treasury and Labor approved restated Bylaws of the Joint Board (the 1981 Bylaws). Sections 3(b) and 3(c) of the 1981 Bylaws provide that the Chairman and Secretary, respectively, will be elected …