ERISARegulationsJan 1, 2017
(f) (f) Preemption of State laws.
(f)(1) (1) Section 514(e)(1) of the Act provides that title I of the Act supersedes any State law that would directly or indirectly prohibit or restrict the inclusion in any plan of an automatic contribution arrangement. For purposes of section 514(e) of the Act and this paragraph (f),…
IRCProposed Rules (FR)Proposed Jan 13, 2025related by meaning
end paper submissions to: CC:PA:01:PR (REG-101268-24), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations, call Jessica S. Weinberger at (202) 317-6349 or Jason E. Levine at (202) 317-4117; concerning submi…
IRCCourt RulingsOct 19, 2010related by meaning
re to pay his 2004 taxes; and
(4) whether the Court should impose a penalty under section
6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or
delay.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the par…
IRCCourt RulingsFeb 6, 2024related by meaning
icipation. Id.
Thus, even though the withdrawal from the taxpayer’s Keogh account
was involuntary and the funds were paid directly to the USA pursuant to the Commissioner’s levy, the taxpayer was deemed to constructively
receive the funds under section 72(m)(4)(A).
4
In Murillo , 75 T.C.M. (CCH) at 1564, the taxpayer p…
IRCCourt RulingsMar 7, 2019
…/RC
Equipment--Krom. 12/19/2003 10,250 10,250 -- -- -- E
- 29 -
[*29]
Telephone System 12/31/2003 4,514 4,514 -- -- -- F
TC33D Equipment--
Krom. 9/29/2004 14,500 14,500 -- -- -- -- -- E
GPS System 10/7/2004 1,739 1,739 -- -- -- -- -- E
BA463 2005 Mustang 11/20/2004 28,617 -- -- 2,960 4,700 2,850 1,675 E
Equipment--Sear…
IRCCourt RulingsJul 31, 2000
; King’s Ct. Mobile Home
Park, Inc. v. Commissioner
, 98 T.C. 511, 514-515 (1992); Paula
Constr. Co. v. Commissioner
, 58 T.C. 1055, 1058-1059 (1972), affd. without published opinion 474 F.2d 1345 (5th Cir. 1973).
The intent is not found, as petitioners would have it, at or
after the time that respondent challenges the…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJan 27, 2005
re, 10 percent of that amount is
$11,514.30. The deficiency determined in the notice of
deficiency is $10,824. At trial, counsel for respondent agreed that this was an incorrect computation but declined to move to
increase the deficiency to $11,514.30.
72(t) and determined a deficiency of $10,824 for that tax and the
n…
IRCCourt RulingsSep 19, 2019related by meaning
e. Because petitioner raises only a legal issue, we
decide whether he is liable for the deficiency without regard to the burden of
proof.
II. Analysis Gross income generally includes distributions from an IRA under the
provisions of section 72. Sec. 408(d); see Sears v. Commissioner, T.C. Memo.
2010-146. Section 72(t)(…
IRCCourt RulingsApr 14, 2005
… to establish his/her claim by a preponderance of the
evidence. Helvering v. Taylor
, 293 U.S. 507, 514-515 (1935); see
also Pittman v. Commissioner
, 100 F.3d 1308, 1317 (7th Cir.
1996), affg. T.C. Memo. 1995-243; Page v. Commissioner
, 58 F.3d
1342, 1347-1348 (8th Cir. 1995), affg. T.C. Memo. 1993- 398.
Without regar…
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
IRCCourt RulingsMay 14, 2009
…ort furnished from all sources for the year at issue . See
Blanco v . Commissioner , 56 T .C . 512, 514 (1971) . If the total
support is not shown and cannot be reasonably inferred from th e
competent evidence available, then it is not possible to conclude
that petitioners furnished more than one-half of RMW's support …
IRCCourt RulingsOct 9, 1997related by meaning
Held, further
, the creation of a reserve under
sec. 419A(c)(2), I.R.C., requires the accumulation of
assets and does not result from the accrual of a liability. General Signal Corp. & Subs v.
Commissioner
, supra
, followed.
4. Held, further
, because P's contributions to
its VEBA during 1986 did not result in the cre…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsSep 25, 1996
…nts would
be appropriate if we so determine.
After the termination, MPC still owed MIT 85 some $755,514.
- 75 -
Fred recommended that the partnership distribute this $755,514
receivable to its partners. The partners were thereafter listed
as creditors against the estate in bankruptcy of Anthony S. and
Miriam A. Bucci (…
IRCCourt RulingsNov 25, 2002related by meaning
ot entitled to IRA contribution
deductions because they did not substantiate their IRA
deductions. Finally, respondent determined that petitioners are liable for an accuracy-related penalty due to a substantial
understatement of income tax.
Discussion
In general, the determinations of the Commissioner in a
notice of de…
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
78 FR 13797 — Ex Parte Cease and Desist and Summary Seizure Orders-Multiple Employer Welfare Arrangements ERISAFinal Rules (FR)Mar 1, 2013
…ions) and that offers health insurance coverage to the public and employers at large. ERISA section 514(b)(6) makes clear that the States can regulate any MEWA, even a MEWA that is an ERISA-covered plan. The Department retains shared jurisdiction with the States. In some States, some MEWAs are permitted to operate if t…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018related by meaning
ted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business, and no comments were received. Drafting Information
The principal authors of these regulations are Charles Gorham and Karin Gross of the Office of Associate Chief Counsel (Income Tax and Accounting). …
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…