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82 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 78 T.C. 930; 78 T.C. No. 66 — Hauser v. Comm'r
    IRCCourt RulingsJun 9, 1982
    eir members. This will widen the availability of the retirement savings deduction. [ H. Rept. 93-807, at 126-127 (1974), 1974-3 C.B. (Supp.) 361-362.] Congress enacted the section 219 active participant requirement so that the IRA provisions would narrowly deal with the perceived inequity in the prior law. Accordingly,…
  2. 82 FR 8813 — Adjustment of Civil Penalties
    PBGCFinal Rules (FR)Jan 31, 2017related by meaning
    17-11. The adjusted maximum amounts are $2,097 for section 4071 penalties and $279 for section 4302 penalties. Compliance With Regulatory Requirements The Office of Management and Budget has determined that this rule is not a “significant regulatory action” under Executive Order 12866 and therefore not subject to their…
  3. PBGCRegulationsJul 1, 2019related by meaning
    [Reserved]
  4. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976
    …ension benefits, or nonpension benefits plus a lower level of pension benefits. Cf. H. Rept. No. 93-807, p. 48, 1974-3 C.B. Supp. 283; George Loevsky, supra at 1151. To be sure, this eventually became a matter of concern for Congress. H. Rept. No. 93-807, p. 48, 1974-3 C.B. Supp. 283. But it was not until the enactment…
  5. IRCCourt RulingsAug 3, 1979
    … areas,” the report of the Committee on Ways and Means of the House of Representatives (H. Rept. 93-807, to accompany H.R. 12855, p. 4, (1974), 1974-3 C.B. (Supp.) 236, 239) stated as follows: Discrimination against individuals not covered by pension plans. — Individuals who are outside of qualified pension plans have …
  6. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    that this case is appropriate for summary adjudication. B. Unreported Income The IRS' determinations in a notice of deficiency are generally presumed correct, and the taxpayer bears the burden of proving those determinations erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). The IRS can prove an und…
  7. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    …ther liability items properly attributable to such variable contracts. As a general matter, section 807 provides that increases in the life insurance reserves of a life insurance company are deductible and decreases in the life insurance reserves are includible in income. However, section 817(a) provides that for purpo…
  8. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    )(i), as contained in 26 CFR part 1, revised as of April 1, 2024. Douglas W. O'Donnell, Deputy Commissioner. Approved: April 2, 2024. Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  PLR 200923001 (February 26, 2009). Back to Citation 2.   See also STAFF OF THE JOINT COMM. ON TAX'…
  9. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023related by meaning
    26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-12T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-13T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f). * * * * * Section 1.861-14T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 77…
  10. 96 T.C. 644; 96 T.C. No. 24 — O'Malley v. Commissioner
    IRCCourt RulingsApr 15, 1991related by meaning
    outheast & Southwest Areas Pension Fund v. Central Transport, Inc., 472 U.S. 559, 570 (1985); Donovan v. Mazzola, 716 F.2d 1226, 1231 (9th Cir. 1983). The basis for the liability of a disqualified person for the excise tax under section 4975(a) and (b), i.e., participation, is not the same as the basis for liability of…
  11. 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 …
  12. 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…
  13. 29 C.F.R. § 2570.42(d) — Notice of proposed exemption.
    ERISARegulationsApr 8, 2024related by meaning
    (d) (d) If the proposed exemption includes relief from the prohibitions of ERISA section 406(b), Code section 4975(c)(1)(E) or (F), or FERSA section 8477(c)(2), inform interested persons who are materially affected by the grant of the exemption of their right to request a hearing under § 2570.46 and establish a deadlin…
  14. 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…
  15. 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, …
  16. 29 C.F.R. § 4000.28 — [Reserved]
    PBGCRegulationsDec 7, 2023related by meaning
    [Reserved]
  17. PLR 200737046 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsSep 14, 2007related by meaning
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  18. 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…
  19. 29 C.F.R. § 4000.26(b) — What if I use a commercial delivery service?
    PBGCRegulationsJan 1, 2017
    …t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
  20. 29 C.F.R. § 4000.41 — What are these computation-of-time rules about?
    PBGCRegulationsJan 22, 2018
    …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 computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…