76 FR 18388 — Single-Employer Plan Termination Initiated by PBGC PBGCFinal Rules (FR)Apr 4, 2011
…ns of the administrative record that are prohibited from disclosure under the Privacy Act, 5 U.S.C. 552a.
(ii) A plan administrator or plan sponsor that has received notification pursuant to paragraph (b)(1) of this section may seek a court order under which those portions of the administrative record that contain conf…
IRCCourt RulingsFeb 18, 1997related by meaning
s from petitioner's IRA's in
the total amount of $181,481. Of this amount, petitioners
reported $8,762 as the taxable amount.
The Notice of Deficiency In the notice of deficiency, respondent determined that the
difference between the amount distributed from petitioner's IRA's
(i.e., $90,662.11 + $90,818.53 = $181,480.6…
89 FR 96531 — Privacy Act Regulation; Exemption for Legal Case Management Records PBGCFinal Rules (FR)Dec 5, 2024
…
Specific exemptions: Legal Case Management.
(a)
Exemption.
Under the authority granted by 5 U.S.C. 552a(k)(2), PBGC hereby exempts the system of records entitled “PBGC-19, Office of Negotiations and Restructuring/Office of General Counsel Case Management System” from the provisions of 5 U.S.C. 552a(c)(3), (d), (e)(1),…
IRCCourt RulingsMay 23, 1979related by meaning
oner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960). For all of the above reasons, we have no difficulty in holding that the pension plan contribution made by petitioner’s wholly owned subchapter S corporation and deducted…
89 FR 84314 — Privacy Act Regulation; Exemption for Legal Case Management Records PBGCProposed Rules (FR)Proposed Oct 22, 2024
…
Specific exemptions: Legal Case Management.
(a)
Exemption. Under the authority granted by 5 U.S.C. 552a(k)(2), PBGC hereby exempts the system of records entitled “PBGC-19, Office of Negotiations and Restructuring/Office of General Counsel Case Management System-PBGC” from the provisions of 5 U.S.C. 552a(c)(3), (d), (e…
IRCCourt RulingsJan 3, 2011related by meaning
ly, we will' not
look into respondèntis .alleged failure to issues a 30-day letter,
NId.
As to whether the notice of deficiency; is invalid behause it insufficiently sets forth respondent s pdsitior section 7522(a)
requires that the notice "describe the basis for, änd identify
the amoiints (if any) of, the taxsdue inte…
IRCFinal Rules (FR)Dec 18, 2024
…tinues to read as follows:
Authority:
80 Stat. 379; sec. 3, 60 Stat. 238, as amended; 5 U.S.C. 301, 552.
2. Add subpart A to read as follows:
Subpart A—Freedom of Information Act
§§ 323.1 through 323.5
[Designated as Subpart A]
3. Designate §§ 323.1 through 323.5 as subpart A.
4. Revise the first sentence of § 323.1 to…
IRCCourt RulingsMar 9, 2011related by meaning
s not contested any
part. of Mr. Renkel-'s account of the Transaction. Sincesthere is
no disagreement as to what happened, de do not see whyrdiscovery is necessary. Respondent's professed'need.for discovery is
nothing more than a fishing- expedition. As iwe have previously
warned: "tax cases are to be thoroughlysingest…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…04,598. Additionally, 730 non-fatal overdoses × 75.64 percent overdose treatment and release rate = 552 non-fatal overdose treatment and releases prevented. $12,868 per non-fatal overdose requiring treatment and release × 552 non-fatal overdoses requiring treatment and release = $7,109,073. As such, the total benefit e…
IRCCourt RulingsNov 30, 1981related by meaning
5.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable year in issue. Since respondent asserts that no return was filed by petitioners, respondent asserts a deficiency in the full amount of the asserted income tax liability (sec. 6211) and…
IRCCourt RulingsNov 13, 2012related by meaning
ommissioner, T.C. Memo. 2004-287 (the taxpayer was not entitled to
- 5 -
claim the section 72(t)(2)(A)(iii) disability exception with respect to early distributions from his qualified retirement plan on account of his wife's disability
because she was never an employee of the taxpayer's employer; their residence in
a c…
T.C. Memo. 2014-109 — Leslie J. Molinet Petitioner, and Michael F. Molinet, Intervenor v. Commissioner IRCCourt RulingsJun 9, 2014related by meaning
$31,000.00)" to intervenor. Intervenor also became obligated to pay petitioner
child support. Both parties were represented by counsel in the divorce proceedings, and both parties and their counsel signed the final judgment.
II. Request for Innocent Spouse Relief
On March 8, 2011, petitioner filed Form 8857, Request f…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsMar 15, 2011related by meaning
ner, T.C. Memo. 2005-70.
Section 401(a) sets forth the requirements that must be met
by a trust forming part of a profit-sharing plan in order for the trust to be eligible for favorable -tax treatment. Section
7476(a) confers jurisdiction on this Court to issue declaratory
judgments as to the initial and continuing qua…
IRCCourt RulingsNov 7, 1996related by meaning
in the
- 11 -
(...continued)
2085, 2481-2483. It was subsequently renumbered by sec.
1011A(g)(1)(A) of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3479. Because the
applicable regulation does not reflect the statutory renumbering,
the regulation appears as sec. 54.4981A-1T, Te…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsFeb 22, 1989related by meaning
ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
IRCCourt RulingsJan 27, 2014related by meaning
T.C. Memo. 2014-14
UNITED STATES TAX COURT
RIES ENTERPRISES, INC., Petitioner y. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 9941-11. Filed January 27, 2014.
Mark Eldridge (an officer),' for petitioner.
David Weiner, John Q. Walsh, Jr., and Elizabeth A. Carlson, for respondent.
MEMORANDUM OPINION
KROUPA, Ju…
IRCCourt RulingsJun 20, 2024related by meaning
tioner requested
distribution s from his retirement accounts and received $45,921 and
$91,103 from TIAACREF Brokerage and TIAA Administrative Services LLC, respectively , for a total of $137,024.
O n December 5, 2019, the property was transferred to petitioner
as the sole owner for the sum of $130,000. Petitioner was 5…