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Go to T.C. Memo. 2019-95 (not yet in the library — opens the official source)
82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec…
    IRCTreasury DecisionsAug 12, 2024
    …guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on December 20, 2019, as Division O of the Further Consolidated Appropriations Act of 2019, Pub. L. 116-94, 133 Stat. 2534 (2019), and by section 107 and various other sections of the SECURE 2.…
  3. 89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    nd in its text, PTE 2020-02 has been broadly amended to encompass compensation for advice irrespective of the product recommended. Back to Citation 6.  ERISA section 408(a) and Code section 4975(c)(2), expressly permit the Department (through the Reorganization Plan No. 4 of 1978) to grant “a conditional or uncondition…
  4. Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24…
    IRCNoticesJun 1, 2026related by meaning
    uter limits of the mandatory postponement period could be when a disaster declaration omits an ending date or is extended. Abdo, 162 T.C. at 169 n.13. The IRS disagrees with the Tax Court’s holding that the phrase “in the same manner” in former section 7508A(d) is unambiguous and will continue to defend its interpretat…
  5. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    …not necessarily disabled within the meaning of I section 72(m) (7). See Kopty v. Commissioner, T.C. Memo; 2007-343 (taxpayer who received long-term disability benefits from the U.S. Social Security Administration nct disabled within the' meaning of section 72(m) (7)), affd. 313 Fed. Appx. 333 (D.C. Cir. 2009); see also…
  6. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  7. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …olidated return for a year is referred to as a consolidated group. 26 C.F.R. sec. 1.1502-1(h), (a) (2019). A consolidated group has only one income tax liability for the year. Sec. 1503(a); 26 C.F.R. sec. 1.1502-2(a) (2019). Each member of a consolidated group is severally liable for the income tax. Sec. 1503(a); 26 C.…
  8. 89 FR 64538 — Quality Control Standards for Automated Valuation Models
    IRCFinal Rules (FR)Aug 7, 2024
    …38.   Id. Interagency Statement on the Use of Alternative Data in Credit Underwriting, OCC Bulletin 2019-62 (Dec. 3, 2019); Federal Reserve CA Letter 19-11 (Dec. 12, 2019); FDIC FIL-82-2019 (Dec. 13, 2019); NCUA Letter 19-CU-04 (December 2019); CFPB, Federal Regulators Issue Joint Statement on the Use of Alternative Da…
  9. Notice 2015-39 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-m…
    IRCNoticesJun 1, 2015related by meaning
    ictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations. EMPLOYEE PLANS Notice 2015–39 Notice 2015–39 This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-month avera…
  10. T.C. Memo. 2020-147 — Ram Ratan Sharma & Shakuntala Sharma v. Commissioner
    IRCCourt RulingsOct 29, 2020related by meaning
    SEC T.C. Memo. 2020-147 UNITED STATES TAX COURT RAM RATAN SHARMA AND SHAKUNTALA SHARMA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19466-17. Filed October 29, 2020. Ram Ratan Sharma and Shakuntala Sharma, pro sese. Mayer Y. Silber, Elizabeth A. Carlson, and Stanislaw Balazia, for respondent.…
  11. 85 FR 82798 — Prohibited Transaction Exemption 2020-02, Improving Investment Advice for Workers & Retirees
    ERISAFinal Rules (FR)Dec 18, 2020
    …  SEC Standards of Conduct Rulemaking: What It Means for RIAs, Investment Adviser Association (July 2019), https://higherlogicdownload.s3.amazonaws.com/​INVESTMENTADVISER/​aa03843e-7981-46b2-aa49-c572f2ddb7e8/​UploadedImages/​resources/​IAA-Staff-Analysis-Standards-of-Conduct-Rulemaking2.pdf. Back to Citation 164.  Thi…
  12. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    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…
  13. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …18 March 17, 2017 levels. After November 2, 2015 After January 2, 2018 but on or before January 23, 2019 January 2, 2018 levels. After November 2, 2015 After January 23, 2019 January 23, 2019 levels. Civil Monetary Penalties for Other DOL Programs Violations occurring Penalty assessed Which penalty level applies On or …
  14. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    et interest rate for the use of money shall be the higher of the rate on the date of the prohibited transaction or the rate on the date of correction. If a prohibited transaction is not corrected within the taxable period, disqualified persons participating in the prohibited transaction become liable for a second-tier …
  15. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …ork Billing for Privately Insured Patients Receiving Care in In-Network Hospitals. JAMA Intern Med. 2019; 179(11):1543-1550 (2019). doi:10.1001/jamainternmed.2019.3451. Back to Citation 109.  Centers for Medicare and Medicaid Services. “Emergency Medical Treatment & Labor Act (EMTALA).” (March 2021). https://www.cms.go…
  16. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    ill be forwarded to EP or EO Technical with the request for the TAM. Taxpayer is encouraged to submit statement if Service initiates request for a TAM (2) If the request for a TAM is initiated by an EP or EO Examinations office or by an EP or EO Determinations office or by an appeals office, the taxpayer is encouraged …
  17. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …) and 83 FR 41144, 41686 (Aug. 17, 2018), respectively. Back to Citation 50.  84 FR 30849 (Jun. 27, 2019). The Executive order was issued on June 24, 2019 and was published in the Federal Register on June 27, 2019. Back to Citation 51.  84 FR 65524 (Nov. 27, 2019). Back to Citation 52.  84 FR 65524, 65564 (Nov. 27, 201…
  18. 85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA
    ERISAFinal Rules (FR)May 27, 2020
    …ment Size Class, 2010-2016. Back to Citation 134.  Cerulli, supra note 128. Back to Citation 135.   2019 Defined Contribution Benchmarking Survey Report, Deloitte, 2019. Back to Citation 136.   2019 Defined Contribution Benchmarking Survey Report, Deloitte, 2019, at 20. (In 2015, 50 percent of plan sponsors reported to…
  19. Notice 2022-33 — Notice 2022-33 extends the deadlines for amending a retirement plan or IRA to reflect the provisions of Division O of the Further Consolidated Appropriations A…
    IRCNoticesAug 22, 2022
    …c. 2016-37 are to Rev. Proc. 2016-37, as modified by Rev. Proc. 2017-41, 2017-29 IRB 92, Rev. Proc. 2019-20, 2019-20 IRB 1182, Rev. Proc. 2020-40, 2020-38 IRB 575, and Rev. Proc. 2021-38, 2021-38 IRB 425. 3 For purposes of this notice, references to Rev. Proc. 2019-39 are to Rev. Proc. 2019-39, as modified by Notice 20…
  20. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…