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86 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999
    …es on Thoburn v. Commissioner , 95 T.C. 132, 139 (1990), and Janpol v. Commissioner , 101 T.C. 518, 529 (1993), as support for this contention. In Thoburn , the Court paraphrased the regulations' "amount paid" language as "interest actually charged". See Thoburn v. Commissioner , supra at 139. The Court's statement is …
  2. I.R.C. § 408(e)(6) — Individual retirement accounts
    IRCCode / StatuteJan 6, 2025related by meaning
    (e)(6) (6) Commingling individual retirement account amounts in certain common trust funds and common investment funds Any common trust fund or common investment fund of individual retirement account assets which is exempt from taxation under this subtitle does not cease to be exempt on account of the participation or …
  3. T.C. Memo. 2007-348 — Charles R. Cutler v. Commissioner
    IRCCourt RulingsNov 26, 2007
    …al fact. Dahlstrom v. Commissioner , 85 T.C. 812, 821 (1985); Naftel v. Commissioner , 85 T.C. 527, 529 (1985). The Court will view any factual material and inferences in the light most favorable to the nonmoving party. Dahlstrom v. Commissioner , supra at 821; Naftel v. Commissioner , supra at 529. Summary judgment is…
  4. 76 FR 69126 — Graduated Retained Interests
    IRCFinal Rules (FR)Nov 8, 2011related by meaning
    sthroughs and Special Industries), IRS. List of Subjects in 26 CFR Part 20 Estate taxes Reporting and recordkeeping requirements ( printed page 69128) Adoption of Amendments to the Regulations Accordingly, 26 CFR part 20 is amended as follows: PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Paragra…
  5. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    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.…
  6. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    would otherwise result from the deferral of tax on the earnings in the IRA. See - 18 - sec. 4973. Additionally, Congress continued to fully tax excess contributions upon distribution, despite the fact that such contributions were made with after-tax dollars. H. Conf. Rept. 93-1280, supra at 340, 1974-3 C.B. at 501; H. …
  7. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996
    …act and that a decision may be rendered as a matter of law. 3 Naftel v. Commissioner , 85 T.C. 527, 529 (1985). The moving party bears the burden of proving that there - 3 - is no genuine issue of material fact. Marshall v. Commissioner , 85 T.C. 267, 271 (1985); Naftel v. Commissioner , supra at 529. The facts are vie…
  8. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026related by meaning
    URY Internal Revenue Service Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 54 as follows: PART 54—PENSION EXCISE TAXES 1. The authority citation for part 54 continues to read as follows: Authority: 26 U.S.C. 7805, unless otherwise noted. 2. Section 54.9831-1 is amended by— a. Revising pa…
  9. T.C. Memo. 2005-133 — Gloria Yuen-Mee Ho & Alexander Chi-Shun Tsang v. Commissioner
    IRCCourt RulingsJun 2, 2005related by meaning
    payer is entitled to deduct the amounts that the taxpayer contributes to an IRA. See sec. 219(a). The deduction, however, may not exceed the lesser of (1) $2,000 or (2) an amount equal to the compensation includable in the taxpayer's gross income. See sec. 219(b)(1). If, for any part of a taxable year, a taxpayer or th…
  10. Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum…
    IRCRevenue RulingsNov 26, 2007related by meaning
    INCOME TAX T.D. 9362 T.D. 9362 Temporary and proposed regulations under section 905 of the Code provide rules relating to a United States taxpayer's obligation to notify the Internal Revenue Service of a foreign tax redetermination, which is a change in foreign tax liability that may affect the taxpayer's foreign tax c…
  11. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …29 CFR 579.1(a)(2) $1,964 $2,014. WHD Fair Labor Standards Act Child Labor 29 CFR 570.140(b)(1) $12,529 $12,845. WHD Fair Labor Standards Act Child Labor 29 CFR 579.1(a)(1)(i)(A) $12,529 $12,845. WHD Fair Labor Standards Act Child Labor that causes serious injury or death 29 CFR 570.140(b)(2) $56,947 $58,383. WHD Fair …
  12. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    n 72(t) imposes an additional 10% tax on early distributions from a qualified retirement plan, including an IRA, made to a taxpayer before she attains the age of 59½. See secs. 72(t)(1), (2)(A)(i), 4974(c)(4). Mrs. Gebman had not attained the age of 59½ when she received the distributions at issue. The IRA distribution…
  13. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    begin with section 4973. Section 4973 Section 4973(a) imposes a 6-percent excise tax on excess contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as a deduction under section 219 (computed without regard to section - 27 - 219(g)), exclusive of amounts p…
  14. Rev. Proc. 2014-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela…
    IRCRevenue ProceduresJan 2, 2014
    … status or results in unrelated business income. Not on qualification of state run programs under § 529 .13 EO Technical will not issue letter rulings as to whether a state run tuition program qualifies under § 529. Not on UBIT issues involving certain investments of a charitable lead trust
  15. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    198 99 (1931); H.R.Rep. No. 708, 72nd C ong., 1939-1 C.B. (Part 2) 457, 490-91; S.Rep. No. 665, 72nd Cong., 1939-1 C.B. (Part 2) 496, 532. The Supreme Court has recognized this purpose on several occasions. In United States v. O'Malley , 38 3 U.S. 6 27, 631, 86 S. Ct. 1123, 1126, 16 L. Ed. 2d 45 ( 1966), it was stated …
  16. Rev. Proc. 2013-4 — Rulings and information letters; issuance procedures. Revised procedures are provided for furnishing ruling letters, information letters, etc., on matters rela…
    IRCRevenue ProceduresModified Jan 2, 2013
    … status or results in unrelated business income. Not on qualification of state run programs under § 529 .13 EO Technical will not issue letter rulings as to whether a state run tuition program qualifies under § 529. Not on UBIT issues involving certain investments of a charitable lead trust
  17. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    rmed in the employ of the United States further requires that the service be covered by a retirement system established by a law of the United States. We note that amendments made to the employment tax provisions subsequent to the years in issue have been interpreted in a manner inconsistent with our holding. See sec. …
  18. Rev. Rul. 2009-2 — 2009 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2009 are provided for use in …
    IRCRevenue RulingsJan 12, 2009
    …his notice provides guidance regarding the restriction on investment direction described in section 529(b)(4) of the Code. The notice permits a change in investment strategy for a section 529 account twice in calendar year 2009. Notice 2001-55 modified.
  19. 29 C.F.R. § 4000.21 — What are these rules for determining the filing or issuance date about?
    PBGCRegulationsJan 1, 2017
    …r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
  20. Notice 2025-68 — Notice of intent to issue regulations with respect to section 530A Trump accounts
    IRCNoticesDec 22, 2025related by meaning
    …unt (or, if that person is the account beneficiary’s estate, then the account beneficiary). Section 529A(b)(2)(B) was amended by section 70204(a)(2)(A) of OBBBA to exclude qualified ABLE rollover contributions from the annual contribution limits for an ABLE account. Q. E-1: Is a trustee of a Trump account required to h…