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92 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 79 FR 76931 — Amendments to Excepted Benefits
    IRCProposed Rules (FR)Proposed Dec 23, 2014
    …o after the date wraparound coverage is first offered). * * * * * Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
  2. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013related by meaning
    h respect to petitioner's interest income. IV. Claimed Expense Deductions Deductions are a matter of legislative grace, and ordinarily a taxpayer must prove that he is entitled to the deductions he claims. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). A taxpayer must maintain records to substantiate claimed de…
  3. 81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements
    IRCProposed Rules (FR)Proposed Jun 1, 2016
    estrictions. Section __.110(b) requires preparation of a plan for remediation to achieve an NSFR of at least equal to 1.0, as required under § __.100. Section __.130 requires that a depository institution holding company subject to the proposed NSFR or modified NSFR requirements publicly disclose its NSFR calculated on…
  4. 80 FR 13995 — Amendments to Excepted Benefits
    IRCFinal Rules (FR)Mar 18, 2015
    …the date limited wraparound coverage is first offered). * * * * * Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
  5. 79 FR 59130 — Amendments to Excepted Benefits
    IRCFinal Rules (FR)Oct 1, 2014
    … no cost sharing under the employee assistance program. * * * * * Footnotes 1.  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public La…
  6. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171 (1931)), aKg T.C. Memo. 1982-209. With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed below, we reject petitioners' broadest argument--that the substance doctrines have no…
  7. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    …e service: one has agreed to accept $85, two have agreed to accept $100, two have agreed to accept $110, three have agreed to accept $120, and one has agreed to accept $150. Under the agreement, the plan agrees to pay the providers 80% of the agreed amount, with the individual receiving the service responsible for the …
  8. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    an excise tax (sec. 4980 of the Code)." (Emphasis added.) Certainly, it would seem highly unlikely that Congress could have intended a mere 10 percent excise tax to replace the tax on income at a substantially higher rate, and there is nothing in the legislative history relating to the increase in the excise rate from …
  9. T.D. 9459 — Final regulations under sections 401(a)(9) and 403(b) of the Code permit a governmental plan to comply with the required minimum distribution rules by using a …
    IRCTreasury DecisionsOct 13, 2009related by meaning
    nt first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements. EXCISE TAX T.D. 9457 T.D. 9457 Final regulations under section 4980G of the Code provide guidance on employer contributions to Health Savings Accounts (HSAs), as amended by the Tax Relief and Health C…
  10. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    gift tax As Mrs. Cadwell would be the' hypotlietical' donorain' thé scehario posited by petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention sec tion 102 (a) , which exc ludes f rom- gros s income the value of property acquired by Égift Howeve…
  11. T.C. Memo. 2014-21 — Alvan L. Bobrow & Elisa S. Bobrow v. Commissioner
    IRCCourt RulingsJan 28, 2014related by meaning
    her authority that would distinguish the Martin cases from the issue presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA - 25 - [*25] distributions is substantial in relation to the weight of the authorities sup…
  12. Treas. Reg. § 1.422-5(e) — Permissible provisions.
    IRCRegulationsSep 9, 2016
    …k on the date of transfer, $1,875 (75 shares at $25 per share), and the amount paid for the stock, $375 (60 shares at $0 per share plus 15 shares at $25 per share)). In addition, A must recognize a capital gain of $675, which consists of $375 ($450, the amount realized from the sale of 15 shares, less A's basis of $75)…
  13. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  14. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  15. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …sted on the policy statements) by the outstanding loan balance. The Trust funded David's loan with $375,000 from Southland, and $125,000 from Lafayette. Because the Trust got its financing from two different sources that had two different interest rates, David executed two promissory notes instead of one. In 2004, a fe…
  16. T.C. Summary Opinion 2003-161 — Martin Edward Caulfield v. Commissioner
    IRCCourt RulingsNov 7, 2003related by meaning
    t petitioner was liable for this additional tax. Respondent determined that the distributions simply constituted income for the amounts set out in the information returns filed by the payor, Sunoco. Moreover, petitioner's health status and his need for the money are not grounds for the exclusion of the distributions fr…
  17. 67 T.C. 906 — Jennemann v. Commissioner
    IRCCourt RulingsMar 7, 1977related by meaning
    ains treatment. This in turn allows a distributee a deduction equal to 50 percent of the gain realized or an alternative tax. See secs. 1201 and 1202. Allowance of a deduction from gross income is not a matter of right or equity but depends upon legislative grace. Helvering v. Ind. Life Ins. Co., 292 U.S. 371, 381 (193…
  18. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …,782 264,725 31,990 (1,429,122) 111,600 Beginning year balance -0-1,766,782 2,031,507 2,063,497 634,375 End of year balance 1,766,782 2,031,507 2,063,497 634,375 745,975 At the close of the taxable year ending December 31, 1984, the National Presto VEBA had total assets of $2,408,732 that consisted of a cash balance in…
  19. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999related by meaning
    penses which are ordinary and necessary and recurring in nature. Respondent relies on Rev. Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring expenses paid by an employer are not deductible under this regulation. We disagree. Our analysis starts at s…
  20. 87 FR 43991 — Examination and Copying of PBGC Records
    PBGCFinal Rules (FR)Jul 25, 2022
    …to FOIA requests. Under the final rule, PBGC is raising its FOIA fee to $54.00 per hour, which is 3.375 times its previous FOIA fee of $16.00 per hour. With the increase of 3.375 times, PBGC anticipates that it will collect roughly between $6,500 and $10,000 in fees annually. Therefore, the increased fees under § 4901.…