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102 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Rev. Rul. 2014-3 — 2014 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2014 are provided for use in …
    IRCRevenue RulingsJan 6, 2014
    …1968 2035 109,764 1969 2036 110,820 1970 2037 111,732 1971 2038 112,584 1972 2039 113,424 1973 2040 114,192 1974 2041 114,840 1975 2042 115,404 1976 2043 115,824 1977 2044 116,124 1978 2045 116,412 1979 2046 116,700 1980 2047 116,904 1981 and Later 2048 and Later 117,000 ATTACHMENT II 2014 ROUNDED COVERED COMPENSATION …
  2. 72 T.C. 117 — Dallas Dental Lab, Inc. v. Commissioner
    IRCCourt RulingsApr 12, 1979related by meaning
    e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
  3. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    …in the present value of the future payment of $100,000 for X’s 2015 taxable year ($82,270 − $0); $4,114 ($86,384 − $82,270) is the increase in the present value of the future payment for X’s 2016 taxable year; $4,319 ($90,703 − $86,384) is the increase in the present value of the future payment for X’s 2017 taxable yea…
  4. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    volution" makes our approach "untenable". See dissenting op. p. 98. Yet the cornerstone of the dissent's analysis appears to be its highly generalized claim that the purpose of a Roth IRA or an FSC is tax avoidance. See 4 pp. 87, 93. We are unaware of any support, textual or otherwise, for such a generalized claim with…
  5. IRCCourt RulingsOct 12, 1978related by meaning
    do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
  6. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    …eased almost 23 times, pre-tax earnings rose about 108 times, and after-tax earnings rose more than 114 times. During such period, the average yearly increase in gross sales was about 57 percent, in pre-tax earnings, 109 percent, and in after-tax earnings, 110 percent. The success of Home Interiors is also illustrated …
  7. 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…
  8. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    claimed medical transportation expenses and that he falls under the exception in section 72(t)(2)(B). As discussed supra Part II.A, petitioner is not entitled to deduct his claimed medical transportation expenses under section 213(a). Therefore, he does not fall under the exception in section 72(t)(2)(B) and he is lia…
  9. 60 T.C. 469; 60 T.C. No. 52 — Estate of Bell v. Commissioner
    IRCCourt RulingsJun 26, 1973
    …e, be deemed a gift * * * * * [Sec. 2512(b).] See also Anna L. Raymond, 40 B.T.A. 244 (1939), affd. 114 F. 2d 140 (C.A. 7, 1940); Maud Gillespie, 43 B.T.A. 399 (1941), reversed on other grounds 128 F. 2d 140 (C.A. 9, 1942); Bowden v. Commissioner, 234 F. 2d 937 (C.A. 5, 1956).
  10. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
  11. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  12. Treas. Reg. § 1.401(a)(5)-1(e)(7) — Special rules relating to nondiscrimination requirements.
    IRCRegulationsMay 18, 2016
    …nce amount under the Social Security Act attributable to A's service for Z is 32/35 × $4,500, or $4,114. Therefore, to satisfy this paragraph (e), the final pay provision in Z's plan may not limit A's otherwise determined normal retirement benefit of $16,000 to less than $15,886 ($20,000 (the amount of X's final pay) m…
  13. Treas. Reg. § 1.401(a)(9)-9(d) — Life expectancy and distribution period tables.
    IRCRegulationsSep 17, 2024
    …3.2 3.1 3.0 3.0 3.0 112 3.7 3.5 3.4 3.3 3.2 3.1 3.0 3.0 3.0 113 3.6 3.5 3.4 3.2 3.1 3.1 3.0 3.0 2.9 114 3.6 3.5 3.3 3.2 3.1 3.0 3.0 2.9 2.9 115 3.6 3.4 3.3 3.2 3.1 3.0 2.9 2.9 2.9 116 3.5 3.3 3.2 3.1 3.0 2.9 2.8 2.8 2.8 117 3.4 3.3 3.1 3.0 2.9 2.8 2.7 2.7 2.7 118 3.3 3.1 3.0 2.8 2.7 2.6 2.6 2.5 2.5 119 3.1 2.9 2.8 2.6 …
  14. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    er. Sec. 1.6662-4(d)(3)(iii), Income Tax Regs. Legal opinions are not authority. The authorities underlying a legal opinion, however, may give rise to substantial authority for the tax treatment of an item. Id. We conclude that the corporate petitioners are not liable for the penalties in dispute. We have agreed with p…
  15. Treas. Reg. § 54.4971(c)-1(h) — Taxes on failure to meet minimum funding standards; definitions.
    IRCRegulationsDec 30, 2016
    …effective date (h)(1)(i) (i) In general. In general, the amendments made to section 4971 by section 114 of the Pension Protection Act of 2006, Public Law 109-280, 120 Stat. 780 (2006), as amended (PPA '06), apply to taxable years beginning on or after January 1, 2008, but only with respect to a plan year that— (h)(1)(i…
  16. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    …er, T.C. Memo. 2018-69, 115 T.C.M. (CCH) 1364, 1375; Bon Viso v. Commissioner, T.C. Memo. 2017-154, 114 T.C.M. (CCH) 178, 180 n. 8; O’Neal v. Commissioner, T.C. Memo. 2016-49, 111 T.C .M. (CCH) 1218, 1228 n.6. 9 [* 9 ] determined income tax deficiencies resulting from the same transactions. Id . at 1294. We rejected th…
  17. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026
    Adjustment Act Improvements Act of 2015, Public Law 114-74, section 701, this amount is generally adjusted annually for inflation. Back to Citation 5.  This amount may be assessed after January 8, 2025, for any noncompliance with a provision covered under section 4071 of ERISA that occurred after November 2, 2015, the …
  18. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    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…
  19. PLR 202136002 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations
    IRCPrivate Letter RulingsSep 10, 2021
    on 114 of the SECURE Act modifies section 401(a)(9) to increase the age on which the determination of required minimum distributions is based from age 70½ to age 72. The amendments made by section 114 of the SECURE Act ap ply to distributions required to be made after December 31, 2019, with respect to individuals who …
  20. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…