88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… = $0.76; The mailing rate is applied in the following calculation: (10,000 IRAs × 5.8%) × $0.76 = $441.
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558. This cost is estimated as: ($301,790 to prepare the termination form + $52,875 to distribute the termination form + $441 for material and postage costs) = $355,106.
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559.
The …
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsDec 8, 1987related by meaning
ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468.
Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
… group in a distribution described in this section 4.01(29) of this revenue procedure. (30) Section 441(i).—Taxable Year of Personal Service Corporations.—Whether the principal activity of the taxpayer during the testing period for the taxable year is the performance of personal services within the meaning of § 1.441-3…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
T.D. 9987 — These regulations provide guidance relating to the minimum present value requirements applicable to certain defined benefit pension plans. These regulations pr… IRCTreasury DecisionsFeb 5, 2024
…nterest rate and applicable mortality table under section 417(e)(3), to a straight life annuity of $441.33 per month payable at normal retirement age. Therefore, under the amendment, the portion of Participant R’s accrued benefit that is not paid in the form of that temporary annuity must be no less than $1,558.67 per …
IRCCourt RulingsMay 19, 1986related by meaning
urt has taken in later cases, such as those noted earlier herein, is a matter that we need not consider. The plain fact is that it is distinguishable. We find support, at least to some extent, for our conclusion that the provision under attack is constitutional in the numerous recent cases interpreting section 2035 wit…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…ed as a result of the transfer meeting the requirements of § 351(a) or § 368(a)(1)(D).
(30)
Section 441(i).—Taxable Year of Personal Service Corporations.—Whether the principal activity of the taxpayer during the testing period for the taxable year is the performance of personal services within the meaning of § 1.441-3…
IRCCourt RulingsMay 12, 1971related by meaning
g $1,000,
may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…ed as a result of the transfer meeting the requirements of § 351(a) or § 368(a)(1)(D).
(30)
Section 441(i).—Taxable Year of Personal Service Corporations.—Whether the principal activity of the taxpayer during the testing period for the taxable year is the performance of personal services within the meaning of § 1.441-4…
ERISARegulationsApr 25, 2023
…port is made as required to be furnished to the administrator by such account or trust under § 2520.103-5(c). Although the statement of assets and liabilities referred to in § 2520.103-5(c) shall be considered part of the plan's annual report, such statement of assets and liabilities need not be filed with the plan's a…
IRCCourt RulingsOct 25, 1961related by meaning
recognized in section' ⅞,1 of. its regulations, set forth above.
See the last sentence of section 405(b) of the Defense Production Act of 1950, supra. We are not here called upon to decide whether taxpayers may appeal from the dis-allowance to us or any other court (see N. A. Woodworth Co. v. Kavanagh, supra; Oak Mfg. …
ERISARegulationsJan 1, 2017
…r which the annual report is made as required to be furnished by such account or trust under § 2520.103-5(c). Although the statement of assets and liabilities referred to in § 2520.103-5(c) shall be considered part of the group insurance arrangement's annual report, such statement of assets and liabilities need not be …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
ERISARegulationsJan 1, 2017
(a) (a) General. Under the authority of sections 103(b)(4), 104(a)(3), 110 and 505 of the Act, an employee benefit plan, some or all of the assets of which are held in a common or collective trust or a pooled separate account described in section 103(b)(3)(G) of the Act and §§ 2520.103-3 and 2520.103-4, is relieved fro…
IRCCourt RulingsMay 23, 2005related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2001,
the taxable year in issue. All monetary amounts are rounded to
the nearest dollar.
T.C. Summary Opinion 2005-62
UNITED STATES TAX COURT
THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v
.
COMMISS…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsMar 20, 1997related by meaning
but did not." Central Tablet Manufacturing
Co. v. United States
, 417 U.S. 673, 690 (1974); Commissioner v.
National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149
(1974). It would be quite intolerable to pyramid the existing
complexities of tax law by a rule that the tax shall be that
resulting from the for…