IRCCourt RulingsDec 11, 2003related by meaning
foregoing statutory
- 19 -
requirements were satisfied for the audit year. Therefore, we
reject petitioner’s claim, raised at trial, to deductions for three dependency exemptions.
VI. Respondent’s Section 72(t) Determination
Section 72(t) provides, in pertinent part, as follows:
SEC. 72(t). 10-Percent Additional Tax on…
IRCCourt RulingsMar 31, 1981related by meaning
taken into account in applying these tests. * * * [H. Rept. 93-807, supra, 1974r-3 C.B. (Supp.) at 285; S. Rept. 93-383, supra, 122. Emphasis added.] Thus, both the statute and the legislative history explaining it clearly indicate that all of the employees of a controlled group are to be considered, without limitatio…
IRCCourt RulingsApr 12, 1979related by meaning
e facts herein with respect to the third category of petitioner’s employees, we hold that regulation to be a reasonable interpretation of the statute. Petitioner is not entitled to increase the limitation on deducti-bility of contributions to the plan by providing for a merely technical allocation at the end of a year …
Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu… IRCRevenue RulingsDec 8, 2003related by meaning
INCOME TAX
Rev. Rul. 2003-122 Rev. Rul. 2003-122
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003.
T.D. 9095 T.D. 9095
REG-136890-02
Final, temporar…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
IRCCourt RulingsJan 8, 2004related by meaning
regardless of
whether petitioner’s employer provided misguided advice, or
whether her retirement plan failed to issue her a properly
completed form,
4 the requirements of section 72(t)(2)(B) must be
- 5 -
4
(...continued)
Form 1040, U.S. Individual Income Tax Return. This line is
labeled “Penalty on early withdrawal of…
ERISARegulationsJun 15, 2018
…d in § 2510.3-2(e). In the case of a controlled group of corporations within the meaning of section 407(d)(5) of the Act, all pension plans sponsored by members of the group shall be considered to be one pension plan.
(g)(3)(iv) (iv) The term “employer” means, for purposes of paragraph (g) of this section, the former e…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsOct 8, 2003related by meaning
tion or compensation is
- 9 -
3
We also note that the legislative history of sec. 404(a),
(b), and (d) supports our construction of that section. That history is generally discussed in detail in Avon Prods., Inc. v.
United States
, 97 F.3d 1435, 1439-1442 (Fed. Cir. 1996), and
Truck & Equip. Corp. v. Commissioner
, 98 …
80 FR 22010 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and B… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
the writer's interest in the proposal. Comments received will be available for public inspection at the above address.
Proposed Amendment to PTE 84-24 Under section 408(a) of the Employee Retirement Income Security Act of 1974, as amended (ERISA) and section 4975(c)(2) of the Internal Revenue Code of 1986, as amended (…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsOct 6, 1988related by meaning
n of the transitional rule and denial of the unlimited marital deduction is, therefore, consistent with, and does not frustrate, congressional intent. Because we have concluded that the marital deduction provision in decedent’s will is a marital deduction formula to which section 403(e)(3) of ERTA applies, the marital …
IRCCourt RulingsJun 30, 2004related by meaning
nnuity described in section
408(b).” Sec. 7701(a)(37) (an individual retirement plan is
commonly referred to as an IRA). Section 72(t)(2)(E) was added by section 203(a) of the Taxpayer Relief Act of 1997, Pub. L.
105-34, 111 Stat. 788, 809. The Report of the Committee on the
Budget refers only to withdrawals from IRAs.…
80 FR 21928 — Definition of the Term “Fiduciary”; Conflict of Interest Rule-Retirement Investment Advice ERISAProposed Rules (FR)Proposed Apr 20, 2015
…ness opinion, or statement of value to—
(i) An employee stock ownership plan (as defined in section 407(d)(6) of the Act) regarding employer securities (as defined section 407(d)(5) of the Act);
(ii) An investment fund, such as a collective investment fund or pooled separate account, in which more than one unaffiliated…
T.D. 9142 — REG-101447-04 Final regulations under section 408(q) of the Code provide requirements relating to deemed IRAs that may be included in qualified employer plans,… IRCTreasury DecisionsAug 23, 2004related by meaning
e to it under the Code solely because of the failure of the deemed IRA.
(h) Definitions. The following definitions apply for purposes of this section: (1) Qualified employer plan. A qualified employer plan is a plan described in section 401(a), an annuity plan described in section 403(a), a section 403(b) plan, or a go…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022related by meaning
be deductible, [it] shall be deductible
under this section, subject, however, to the following
limitations as to the amount s deductible in any year. Thus, in order to be de ductible under section 404(a), compensation
“ must be expenses which would be deductible under section 162
( relating to trade or business expens…