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87 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …ed for less than 10 years, the maximum permissible benefit is reduced proportionately. [H. Rept. 93-807, at 35-36 (1974), 1974-3 C.B. (Supp.) 236, 270-271.] Section 415(a) precludes qualified plans from providing for payment of annual benefits in excess of an amount determined under subsection (b). Section 415(b)(1) es…
  2. 29 C.F.R. § 2570.116 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
  3. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981
    …nd had those deductions disallowed. * * * H. Rept. 93-779 (1974), 1974-3 C.B. 244, 348; H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 341; S. Rept. 93-383 (1973), 1974-3 C.B. (Supp.) 80,191-192. To provide for judicial review of respondent’s determination regarding a retirement plan before a notice of deficiency is …
  4. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  5. 99 T.C. 9; 99 T.C. No. 2 — Vinson & Elkins v. Commissioner
    IRCCourt RulingsJul 14, 1992
    …is concerned, and would be likely to result in cost estimates that are not reasonable. [H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 262.] By deferring to the professional judgment of actuaries in the area of plan funding, Congress expressed its intent that actuaries be afforded a range of latitude in establishing a mix…
  6. 81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    nancial institution, an insurance company, or a broker-dealer. Back to Citation 8.  Cerulli Associates, “Retirement Markets 2015.” Back to Citation 9.  The Department initially proposed an amendment to its regulation defining a fiduciary within the meaning of ERISA section 3(21)(A)(ii) and Code section 4975(e)(3)(B) on…
  7. 98 T.C. 503; 98 T.C. No. 34 — Fowler v. Commissioner
    IRCCourt RulingsApr 22, 1992
    …is mistaken. Section 402(e)(2) was designed to prevent tax avoidance possibilities. See H. Rept. 93-807 (1974), 1974-3 C.B. (Supp.) 236, 387. It embodies a rule covering both interyear and intrayear distributions, including the taxable year. Such being the case, there was no need for an additional intrayear provision, …
  8. 29 C.F.R. § 2570.168 — Decision of the administrative law judge.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
  9. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  10. I.R.C. § 431(c)(6)(D)(ii) — Minimum funding standards for multiemployer plans
    IRCCode / StatuteJan 6, 2025
    … the Secretary which is based on the prevailing commissioners' standard table (described in section 807(d)(5)(A)) 1 used to determine reserves for group annuity contracts issued on January 1, 1993.
  11. 80 FR 22010 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and B…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    e authority of the Secretary of the Treasury to issue administrative exemptions under Code section 4975 to the Secretary of Labor. Back to Citation 3.  For purposes of this amendment, the terms “Individual Retirement Account” or “IRA” mean any trust, account or annuity described in Code section 4975(e)(1)(B) through (F…
  12. ERISA § 304(c)(6)(D)(ii)(I) (29 U.S.C. § 1084) — Minimum funding standards for multiemployer plans
    ERISACode / StatuteJan 6, 2025
    …f the Treasury which is based on the prevailing commissioners' standard table (described in section 807(d)(5)(A) of title 26) 1 used to determine reserves for group annuity contracts issued on January 1, 1993.
  13. PLR 201117012 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsApr 29, 2011
    …), the computation of the exclusion ratio under § 72(b ), or the computation of the reserve under § 807(d). This ruling is directed only to the taxpayer requesting it. Section 6110(k)(3) provides that it may not be used or cited as precedent. In accordance with the Power of Attorney on file with this office , a copy of…
  14. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    (c)(2). Thus, we sustain respondent’s determination on this issue. C. Petitioner’s IRA Deductions As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the burden of proving his or her entitlement to the claimed deductions. 18 Rule 142(a)(1); see New Colonial …
  15. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    …ns for the years at issue: Year Total income Total deductions Taxable income 2003 $1,643,523 $1,550,807 $92,716 2004 1,488,793 1,390,853 97,940 2005 1,688,916 1,693,882 (4,966) 2006 1,903,914 1,884,065 14,883¹4 ¹³ BAI's fiscal year ends June 30. Therefore, all references to BAI's tax years at issue refer to the calenda…
  16. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007related by meaning
    sioner , T .C . Memo . 2001-34 . We recognize that petitioner received his IRA distribution at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable purpose . Unfortunately for petitioner, we are bound by the lis t of statutory exceptions set forth in sectio…
  17. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …2-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1993 $41,807 — $8,361 1994 49,970 — 9,994 We decide the following issues: 1. Whether Neonatology and Lakewood may deduct contributions to their respective plans in excess of the amounts needed to purchase current-year (term) life…
  18. 29 C.F.R. § 2570.68 — Decision of the administrative law judge.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(2) civil penalty proceedings, this section shall apply in lieu of § 18.57 of this title.
  19. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    him . On May 24, 2002, SBC Communications, Inc ., issued a check to petitioner in the amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and $3,367 .11 in California State income tax had been withheld . During 2002, petitioner also received $9,552 …
  20. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…