Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to I.R.C. § 754 (not yet in the library — opens the official source)
75 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  2. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    Petitioner argued that the Hong Kong & Shanghai Banking Corp. owns Midland Bank, a U.S. bank, but this factor does not affect our conclusion regarding the probable situs of any trust created in connection with the IRA funds transfer. On this record, we conclude that petitioner has failed to show that the $17,558 that h…
  3. 89 FR 43675 — Prohibited Transaction Exemption 2006-06 for Services Provided in Connection With the Termination of Abandoned Individual Account Plans
    ERISAFinal Rules (FR)May 17, 2024related by meaning
    section 4975(c)(2) necessitate proposing an amendment to the exemption. Back to Citation 26.   See 29 CFR 2578.1(d)(2)(v). Back to Citation 27.   See Section I(a)(3) of this exemption amendment. Back to Citation 28.   See paragraph 29 CFR 2578.1(c)(3) of the QTA Regulation or in the case of a QTA described in Section …
  4. T.C. Memo. 2017-132 — Jack Howard Taylor v. Commissioner
    IRCCourt RulingsJul 5, 2017related by meaning
    5, and bore a postmark indicating that it was mailed by FedEx Standard Overnight service on July 6, 2015. Since the petition was mailed timely using a - 6 - [*6] designated private delivery service, see Notice 2015-38, 2015-21 I.R.B. 984, it is treated as filed timely, see sec. 7502(a), (f). Discussion I. Overview Gene…
  5. Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2005related by meaning
    amounts set aside by a trust or estate for charitable purposes when there is a possibility that the corpus of the trust or estate may be invaded. (43) Section 664.—Charitable Remainder Trusts.—Whether the settlement of a charitable remainder trust upon the termination of the noncharitable interest is made within a reas…
  6. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    ing, 290 U.S. 111, 115 (1933). Petitioner contends, however, that pursuant to sections 6201(d) and 7491(a) respondent should bear the burden of proof. If a taxpayer asserts a reasonable dispute with respect to an item of income reported on an information return filed by a third party and meets certain other requirement…
  7. T.C. Memo. 2014-108 — Guy M. Dabney & Ann V. Dabney v. Commissioner
    IRCCourt RulingsJun 5, 2014related by meaning
    vit from Chicago Title in which the company admitted fault for the error. Mr. Dabney sold the Brian's Head property and received $127,226 on the sale, after taxes and fees. That amount was wired directly into the Charles Schwab IRA - 6 - [*6] on or around January 28, 2011. Mr. Dabney marked the deposit as a rollover co…
  8. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    under section 72(t). Consistent with a prior determination regarding the section 6015 relief, respondent also conceded that petitioner was entitled to allocate the portion of the 2008 Federal income tax liability attributable to the unreported nonemployee compensation of $16,027 from FedEx to Mr. Scarlett under section…
  9. T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner
    IRCCourt RulingsJun 17, 1998related by meaning
    ir. 1981), affg. 71 T.C. 252 (1978). As we further noted in Harwood v. Commissioner , supra at 258: "Transactions within a family group are subject to special scrutiny, and the presumption is that a transfer between family members is a gift." Section 7520 generally requires (with certain exceptions not applicable here)…
  10. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
  11. 81 T.C. 652; 81 T.C. No. 38 — Doty v. Commissioner
    IRCCourt RulingsSep 28, 1983related by meaning
    nstituted earned income, thereby entitling her to the benefits of section 1348 during the tax years in issue. Decision will be entered under Rule 155. Sec. 1348 was repealed by the Economic Recovery Act of 1981. Pub. L. 97-34, sec. 101(c)(1), 95 Stat. 172,183. Specifically, the marriage settlement agreement provides: "…
  12. U.S. Tax Court — James Thomas & Susan Jane Colegrove v. Commissioner
    IRCCourt RulingsApr 13, 2010related by meaning
    drawal . In a notice of deficiency, respondent determined, inter alia, that the $52,132 .27 distribution from the IRA is includable in income and that petitioners are liable for the 10-percent additional tax on the early distribution pursuant to section 72(t) . Discussion In general, the Commissioner's determination as…
  13. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
  14. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  15. 76 FR 76222 — Filings Required of Multiple Employer Welfare Arrangements and Certain Other Related Entities
    ERISAProposed Rules (FR)Proposed Dec 6, 2011related by meaning
    dds a cross-reference to section 521 of ERISA and § 2560.521 regarding the Secretary's authority to issue cease and desist and summary seizure orders. B. Proposed Amendment to Regulations Under ERISA Section 104(a)(1), 29 U.S.C. 1024(a)(1)