IRCCourt RulingsSep 29, 1992
… plan during 1986, and for funding purposes, Matthews considered his compensation in 1986 to be $73,952.
For the plan years 1985 and 1986, Old Frontier contributed $12,000 and $225,000 to the plan, respectively.
Matthews prepared and signed the Schedules B with respect to the plan for plan years 1985 and 1986. He certi…
76 FR 19285 — Request for Information Regarding Electronic Disclosure by Employee Benefit Plans ERISAProposed Rules (FR)Proposed Apr 7, 2011
… as amended by section 508 of the Pension Protection Act of 2006, Public Law 109-280, 120 Stat. 949-952. Thirteen witnesses testified at this hearing. In response to this hearing, the working group issued the “Report of the Working Group on Participant Benefit Statements.” In this Report, the Working Group recommended …
T.D. 9932 — Section 162(m)(1) of the Internal Revenue Code generally limits to $1,000,000 the allowable deduction for a taxable year for applicable employee remuneration p… IRCTreasury DecisionsJan 19, 2021related by meaning
use the fleet-average valuation rule in § 1.61-21(d)(5)(v) of the Income Tax Regulations or the vehicle cents-per-mile valuation rule in § 1.61-21(e). Notice 2021-5, page 479.
Beginning of Construction for Sections 45 and 48; Extension of Continuity Safe Harbor for Offshore Projects and Federal Land Projects. The notic…
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…
IRCCourt RulingsJan 5, 2017related by meaning
n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20%
5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference
to any SFRs. Even if it did, the literal transcript does not establish that the
requ…
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 RulingsOct 13, 2009related by meaning
Section 72(t) Additional Ta x
Section 72(t) imposes an additional tax on an individual
retirement plan distribution equal to 10 percent of the amount .included in gross income, subject to certain exceptions . Because
the ASLAC distribution is not includable in petitioner's gross
income, petitioner is not liable for th…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
…26-23 1565
2026-33 2026-24 I.R.B. 2026-24 1572
Proposed Regulations:
Article Issue Link Page
REG-101952-24 2026-03 I.R.B. 2026-03 345
REG-110519-25 2026-03 I.R.B. 2026-03 353
REG-132251-11; REG-134219-08 2026-03 I.R.B. 2026-03 358
Proposed Regulations:—Continued
Article Issue Link Page
REG-103430-24 2026-05 I.R.B. 2026…
IRCCourt RulingsJul 8, 2020related by meaning
de imposes a 20% penalty upon the portion of any underpayment of
tax that is attributable to (among other things) "[a]ny substantial understatement of income tax." Sec. 6662(a), (b)(2). An understatement of income tax is "substantial" if it exceeds the greater of $5,000 or 10% of the tax required to be shown on
the ret…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…-pervasive-disparities-access-network-care-continue/fulltext.pdf.
Back to Citation
158.
Susan H. Busch & Kelly Kyanko,
IRCCourt RulingsJan 12, 1998related by meaning
Memo. 1993-61; Ianniello
v. Commissioner
, 98 T.C. 165, 180 (1992); cf. Helvering v.
Mitchell
, 303 U.S. 391, 397 (1938) (holding that the addition to tax for fraud is remedial). Courts have considered the cases
- 8 -
cited by petitioner in the Federal income tax arena and found
that these cases did not apply for purpo…
IRCCourt RulingsDec 16, 1998related by meaning
Instructions to Form 5330,
at 2 ("For taxes due under sections * * * 4975 * * *, file
Form 5330 by the last day of the 7th month after the end of the tax year of the employer or other person who must file this
return."). Although Keystone
later became the law that we
apply herein, we do not impute the knowledge of thi…
IRCCourt RulingsFeb 25, 2016related by meaning
4. Respondent has allowed exactly those amounts as deductions for 2004
and 2005. Petitioner has made no attempts to provide the Court with evidence of any other payments for travel and meals and entertainment expenses. With the
heightened substantiation requirements under section 274 and the lack of
additional document…
88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCProposed Rules (FR)Proposed Aug 3, 2023
…ct; 33(5):63-67.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7077950/.
Back to Citation
201.
Busch, Susan H., and Kelly Kyanko. “Assessment of Perceptions of Mental Health vs Medical Health Plan Networks Among US Adults with Private Insurance.”
JAMA Network Open
4, no. 10 (2021).
Back to Citation
202.
FAQs Part …
IRCCourt RulingsJun 1, 2009related by meaning
account of the employee's disability ; (4) as part of a serie s
e for life ; (5) to a
employee after separation from service after attainment of ag A substantially equal periodic payments m
55 ; (6) as dividends paid with, respect to corporate stoc k
described in section 404(k) ; (7) to an employee for medica l
or (8)…
IRCProposed Rules (FR)Proposed Nov 27, 2019
…health plan) incurring an annual hour burden of 481 hours with an associated equivalent cost of $44,952. For all 1,754 health insurance issuers and 205 TPAs, the total hour burden would be 942,279 hours with and associated equivalent annual cost of $88,061,046. As discussed in the corresponding ICR, requiring a less fr…
IRCCourt RulingsSep 22, 1998related by meaning
nerally presumed correct.
Rule 142(a); Welch v. Helvering
, 290 U.S. 111, 115 (1933).
Furthermore, every item of a person's gross income is subject to Federal income tax unless there is a statute or some rule of law
that exempts the person or the item from gross income. HCSC-
Laundry v. United States
, 450 U.S. 1, 5 (1…
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…uncil/2007-participant-benefit-statements.
Back to Citation
49.
Public Law 109-280, 120 Stat. 949-952.
Back to Citation
50.
See
ERISA Advisory Council Report Working Group on Prudent Investment Process, available at
https://www.dol.gov/agencies/ebsa/about-ebsa/about-us/erisa-advisory-council/2006-prudent-inve…
IRCCourt RulingsAug 13, 1990related by meaning
such transaction.” Our interpretation also is consistent with the regulation cited by respondent, section 301.6501(e)-1(c)(4), Proced. & Admin. Regs. We recognize that petitioners’ argument is supported by a literal reading of section 6501(e)(3). Nevertheless, literal interpretations of statutes must be rejected if th…