88 FR 4900 — Special Financial Assistance by PBGC-Withdrawal Liability Condition Exception PBGCFinal Rules (FR)Jan 26, 2023
…tation plan for withdrawal liability purposes. This issue raises interpretive issues about sections 305(g)(3), 305(d)(1)(B), and 305(f)(1)(B) of ERISA over which the Secretary of the Treasury has interpretive jurisdiction pursuant to section 101 of Reorganization Plan No. 4 of 1978 (5 U.S.C. App.). PBGC is continuing t…
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
IRCCourt RulingsJan 27, 1998related by meaning
articipants, Harold Breslow and Robert Levine,
received their full benefit and petitioner signed an irrevocable
waiver of his rights to Plan benefits. We reject petitioner's argument. Examining the record, we
find no documentary evidence that all rank and file employees
were paid their full vested interest, especially …
IRCCourt RulingsApr 22, 2003related by meaning
to section 72(t)(2)(C) for relief.
It does not appear that any of the statutory exceptions to
the application of section 72(t) apply in this case, and petitioner has not suggested otherwise.
- 7 -
The Court concurs in respondent's determination that
petitioner is subject to the 10-percent additional tax on an
early dis…
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
IRCCourt RulingsMay 12, 1971related by meaning
g $1,000,
may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
IRCCourt RulingsMay 28, 1962related by meaning
ystem. * * * To grant plaintiff the relief prayed for would either be to invoke equity or to legislate, which in either instance, is not our province. Similarly, in the instant case, although the result is harsh, the clear and unambiguous language of the statute requires the conclusion that petitioner is not entitled t…
IRCCourt RulingsJul 8, 2020related by meaning
346, 347 (requiring self-certification that the rollover contribution
was made "as soon as practicable" after the obstacle preventing the rollover was removed). Under these facts, declining to waive the 60-day requirement is not
against equity or good conscience, and petitioner is therefore taxable on the full
$54,500 …
IRCCourt RulingsAug 31, 1978related by meaning
41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
IRCCourt RulingsOct 29, 2013related by meaning
or assets of a plan; (5) act by a disqualified person who is a
- 15 -
[*15] fiduciary whereby he deals with the income or assets of a plan in his own interests or for his own account; or (6) receipt of any consideration for his own
personal account by any disqualified person who is a fiduciary from any party
dealing w…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…et price determined for that episode under § 510.300. We are amending the provisions at 42 CFR 510.305(k)(4) to reflect this change. In addition, in order to account for CJR beneficiaries with a positive COVID-19 diagnosis during a CJR episode that initiates after the adjustments for extreme and uncontrollable circums…
IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000related by meaning
115 T.C. No. 33
UNITED STATES TAX COURT
SHERWIN-WILLIAMS COMPANY EMPLOYEE HEALTH PLAN TRUST, KEY TRUST
COMPANY OF OHIO, TRUSTEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21333-97. Filed November 9, 2000.
Trust (T), a tax-exempt voluntary employees’
beneficiary association described in sec.…
IRCCourt RulingsFeb 26, 1964related by meaning
kly pay period, the Secretary or his delegate shall by regulations prescribe the method of determining the weekly rate at which such amounts are paid. (e) Accident and Health Plans. — For purposes of this section and section 104—
(1) amounts received under an accident or health plan for employees, and
(2) amounts recei…
IRCCourt RulingsJan 3, 2011related by meaning
gift tax As Mrs. Cadwell
would be the' hypotlietical' donorain' thé scehario posited by
petitioner, we conclude that section 2523^ does not" apply. - Petiltionery may have meantato ácite as support for his contention
sec tion 102 (a) , which exc ludes f rom- gros s income the value of
property acquired by Égift Howeve…