89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…
6
7
8
9
10
Total
Value of Reallocation of Assets:
Rule
$29,218
$27,792
$26,380
$24,954
$23,554
$22,267
$21,058
$19,905
$18,839
$17,842
$231,808
−Baseline
29,249
27,570
26,013
24,569
23,229
21,987
20,835
19,767
18,776
17,857
229,851
= Benefits
−31
222
367
385
325
280
223
139
63
−15
1,957
Value of Duplicated Account Fee…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
88 FR 7236 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 2, 2023
…the Treasury share jurisdiction, HHS would account for 50 percent of the burden, or approximately 5,267 hours annually, with an equivalent annual cost of $295,039. DOL and the Department of the Treasury would each account for 25 percent of the burden, as discussed in section VI.E of this preamble.
Table 6—Annual Burden…
IRCCourt RulingsMar 27, 1989related by meaning
oyee contributions (whether voluntary or mandatory), to the extent that the return would reduce the excess amounts in the participant’s account. * * * The Commissioner is required to abide by regulations reasonably based on statute, and his failure to do so will amount to an abuse of discretion. Lansons, Inc. v. Commis…
IRCCourt RulingsOct 9, 1997related by meaning
419A(i) provides that the regulations shall be promulgated by the
Secretary as may be necessary to carry out the purposes of
sections 419 and 419A.
9 If the intent of Congress on a matter is clear, then the
Secretary must give effect to the unambiguously expressed intent
of Congress. Chevron U.S.A. Inc. v. Natural Res…
IRCCourt RulingsNov 26, 1974
… from that employee’s taxable income in the year the amounts were withheld. Cecil W. Taylor, 2 T.C. 267 (1943), affirmed sub nom. Miller v. Commissioner, 144 F. 2d 287 (C.A. 4, 1944); Isaiah Megibow, 21 T.C. 197 (1953), affd. 218 F. 2d 687 (C.A. 3, 1955). However, they argue that the same arguments were not present in …
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 RulingsSep 29, 1987
…,589, and had trust liabilities of $1,070,204; the excess of assets over liabilities was therefore $267,385. As of January 31, 1976, contributions made in excess of petitioner’s liability under the B.B. & Co. Plan for that year amounted to $267,385. Of that amount, $189,539 was attributable to advance contributions, an…
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
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
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
…A–1(f)(2)(ii), subject to the modification that for purposes of applying the references to sections 267(b) and 707(b)(1), the language “20 percent” is not used instead of “50 percent” each place “50 percent” appears in sections 267(b) and 707(b)(1).
(8) Service provider. For purposes of this section, the term service p…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsJun 7, 1984related by meaning
ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u… IRCNoticesApr 6, 2009
$275,386 $262,282 $268,849 $267,848
* Entries reflect the sum of the amounts for the current and later quarters, as illustrated for expected earnings. Average of adjusted fair market value of assets at earlier determination dates and fair market value at valuation date:($275,386 + $262,282 + $268,849 + $267,848 + $274,…
IRCCourt RulingsJan 28, 2014related by meaning
vant facts." Lawinger v. Commissioner, 103 T.C. 428, 440 n.8 (1994).
- 24 -
[*24] Substantial authority exists only when the weight of the authorities supporting the treatment of the tax item is substantial in relation to the weight of
the authorities supporting contrary treatment. Sec. 1.6662-4(d)(3)(i), Income Tax
Re…
Notice 2004-8 — Roth IRAs; abuses; listed transactions. This notice describes certain transactions that are being entered into by individuals, their Roth IRAs, and their busin… IRCNoticesJan 26, 2004
…ment is released to the public: arrangements in which an individual, related persons described in § 267(b) or 707(b), or a business controlled by such individual or related persons, engage in one or more transactions with a corporation, including contributions of property to such corporation, substantially all the shar…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ied in a manner consistent with the
property’s highest and best use. See Mitchell v. United States, 267 U.S.
341, 344 – 45 (1925); Stanley Works & Subs. v. Commissioner, 87 T.C.
389, 400 (1986); Treas. Reg. § 1.170A - 14(h)(3)(ii). A property’s highest
and best use is the most profitable use that is legally permissible…
IRCCourt RulingsDec 2, 1981related by meaning
of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
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…
IRCCourt RulingsMay 9, 2002related by meaning
r 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.
Section 72(t)(2) provides for exceptions to the additional tax,
which petitioners concede are not applicable here.
Petitioners argue…
ERISACode / StatuteJan 6, 2025
…ployee (as defined in section 401(c)(3) of title 26), a member of the family (as defined in section 267(c)(4) of such title) of any such owner-employee, or any corporation in which any such owner-employee owns, directly or indirectly, 50 percent or more of the total combined voting power of all classes of stock entitle…