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…
Rev. Rul. 2008-7 — Accrued benefits; cash balance defined benefit pension plans; section 411 of the Code. This ruling, which pertains to a traditional defined benefit pension pla… IRCRevenue RulingsFeb 19, 2008related by meaning
ection 6689 for failure to notify the IRS of a foreign tax redetermination as required under section 905(c).
Announcement 2008-12 Announcement 2008-12 These documents contain corrections to temporary regulations (T.D. 9362, 2007-48 I.R.B. 1050) and proposed regulations (REG-209020-86, 2007-48 I.R.B. 1075) relating to a…
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…
91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information PBGCProposed Rules (FR)Proposed Jul 21, 2026related by meaning
ns, see 29 CFR part 4003, subpart C. Information filed with a request for consideration is governed by OMB control no. 1212-0063.
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14. These situations are intended to mirror the situations of reasonable cause, legal errors, and pendency of PBGC procedures found in 29 CFR part 4007, App., question 21(b…
IRCCourt RulingsSep 27, 1990related by meaning
. United States, 872 F.2d 564, 568-570 (3d Cir. 1989).
Respondent assumes but does not concede that section 4975(a) imposes a penalty tax. He asserts: the issue in this case would still be whether there is “any expressed or necessarily implied provision or language . . .” (Commissioner v. Acker, 361 U.S. 87, 91 (1959))…
IRCCourt RulingsJun 13, 1977related by meaning
61); Liberty Machine Works, Inc. v. Commissioner, 62 T.C. 621 (1974); Comprehensive Designers International, Ltd. v. Commissioner, 66 T.C. 348 (1976). For plan contributions made after August 1, 1969, however, the standard is that set forth in section 83, viz, whether there exists a substantial risk of forfeiture of th…
IRCCourt RulingsApr 2, 2020related by meaning
period starts with the due
date of the return. Sec. 6501(b)(1).
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[*13] taxpayer signing the Form 4549 waives the section 6213(a) prohibition on the IRS's assessing a tax deficiency without the mailing of a notice of deficiency.
S_e_e sec. 6213(d) (stating that taxpayers may waive restrictions on assessment
provi…
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
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Respondent does not dispute that petit…
ERISACourt RulingsAug 10, 2026
…same standards
employed by the district court in considering the plan administrator’s decision. Id. USCA4 Appeal: 25-1350 Doc: 89 Filed: 08/10/2026 Pg: 9 of 21
10
and the Named Fiduciary with respect to such management and administrative duties
within the meaning of ERISA”) ; J.A. 364 (naming the administrator as a fid…
IRCCourt RulingsMay 30, 1984related by meaning
ents of section 2039(c)(3).
Due to concessions and in order to reflect petitioner’s claim for an overpayment,
Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
ERISACourt RulingsAug 10, 2026
…same standards
employed by the district court in considering the plan administrator’s decision. Id. USCA4 Appeal: 25-2080 Doc: 59 Filed: 08/10/2026 Pg: 9 of 21
10
and the Named Fiduciary with respect to such management and administrative duties
within the meaning of ERISA”) ; J.A. 364 (naming the administrator as a fid…
IRCCourt RulingsJun 17, 1997
… 0-173,550 79,263 128,000
Exemption 100 100 100 100 100
Taxable Income 164,781 199,276 (20,428) (22,898)(182,687)
Total tax 46,139 61,017-0 - - 0 - - 0 -
The Trust paid no benefits in 1988. From 1989 through 1994,
the Trust paid $30,420,770 in employer withdrawal benefits and
DWB's as shown below:
1989
1990
1991
1992
1…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
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3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…explicit prohibition . . The regulation was
effective Aug . 14, 2008 . T .D . .9422,_2009-2 C . B . 898 .
"There is one judicial opinion, involving a case in which
neither the Commissioner nor the United States was a party that
touched on, but did not decide, the issue . See Schuylkil l
Skyport Inn, Inc . v . Rich , Ci…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
IRCCourt RulingsMay 11, 1998
…eral income tax return reflects
adjusted gross income of $136,094.44. Included in that amount is
$4,898.72, which is 85 percent of $5,763.20, the amount of Social
Security benefits received by petitioner Bernice F. Roberts. In
addition, petitioner Richard S. Roberts (petitioner) received
Social Security benefits in 199…
IRCCourt RulingsSep 17, 2009
…h . See sec . 1 .274-5(j)(2), Income Tax Regs . ; Rev .
Proc . 2004-64, sec . 5 .03 , 2004-2 C .B . 898 , 900 ; Rev . Proc . 200578, sec . 5 .03 , 2005-2 C .B . 1177 , 1179 ; see also , e .g ., Nash v .
Commissioner , 60 T .C . 503, 520 (1973) ; Clark v . Commissioner ,
T .C . Memo . 2002-32 . He claims that he is enti…
IRCCourt RulingsMar 13, 2001
…,102
197 9-80 1, 77 4
1980-81 529
1981-82 1,838
1982-83 1,012
1983-84 2,893
1984-85 7,042
1987-88 7,898
Total 36,734
Petitioner's nominal basis in his pension plan is $36,734. Since
petitioner's retirement in July of 1988, he has been receiving a
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gross pension payment of $26,313 annually.
The formula used by the …
IRCCourt RulingsOct 17, 1995
…
2
Petitioners concede that: (1) They overstated their rental
income for 1989 and 1990 by $400 and $898, respectively; (2) they
are not entitled to rental depreciation of $14,673 for 1989; (3)
they are not entitled to deduct capital losses of $3,000 for
1990; (4) they failed to report an individual retirement account
d…