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78 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. PLR 201837004 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsSep 14, 2018
    …equitable interests in the group trust. Rev. Rul. 2014-24, 2014-37 I.R.B. 529 provides that section 1022(i)(1) plans and certain insurance company separate accounts are eligible to participate or invest in an 81-100 group trust if c ertain requireme nts are met. It also notes that an 81-100 group trust is liable for an…
  2. T.C. Memo. 2000-219 — Stephen R. Jones v. Commissioner
    IRCCourt RulingsJul 20, 2000related by meaning
    gross income by the payee or distributee, as the case may be, in the manner provided under section 72.” Petitioner contends that by endorsing his IRA distribution check to his spouse, whom he was divorcing, he complied with an exception to section 408(d)(1) contained in section 408(d)(6), which provides: (6) TRANSFER …
  3. PLR 201650002 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsDec 9, 2016
    …r equitable interests in the gro up trust. Rev. Rul. 2014-24, 2014-2 C.B. 529 provides that section 1022(i)(1) plans and certain insurance company separate accounts are eligible to participate or invest in an 81-100 group trust if certain requirements are met. It also notes that an 81-100 group trust is liable for any …
  4. PLR 201650003 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsDec 9, 2016
    …ir equitable interests in the group trust. Rev. Rul. 2014-24, 2014-2 C.B. 529 provides that section 1022(i)(1) plans and certain insurance company separate accounts are eligible to participate or invest in an 8 1-100 group trust if certain requirements are met. It also notes that an 81-100 group trust is liable for any…
  5. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  6. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …its. Knetsch v. United States , 364 U.S. 361, 365-366 (1960); Karr v. Commissioner , 924 F.2d 1018, 1022-1023 (11th Cir. 1991), affg. Smith v. Commissioner , 91 T.C. 733 (1988). Petitioners bear the burden of proving that the challenged transactions were not shams. Rule 142(a); Sheldon v. Commissioner , 94 T.C. 738, 75…
  7. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007related by meaning
    sioner , T .C . Memo . 2001-34 . We recognize that petitioner received his IRA distribution at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable purpose . Unfortunately for petitioner, we are bound by the lis t of statutory exceptions set forth in sectio…
  8. T.C. Memo. 2016-29 — Mark Vandenbosch & Julie Vandenbosch v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    …T.C. 48 (2001), af[d, 55 F. App'x 476 (9th Cir. 2003); see also Throndson v. Commissioner, 457 F.2d 1022, 1024-1025 (9th Cir. 1972), af[g Schmitz v. Commissioner, 51 T.C. 306, 315-316 (1968). 23Major v. Commissioner, 76 T.C. 239, 247 (1981); Haas & Assocs. Accountancy Corp. v. Commissioner, 2000 WL 800474, at *4. - 21 …
  9. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015
    …is divorce); sm INS v. Ventura, 537 U.S. 12, 14-18 (2002); SKF USA, Inc. v. United States, 254 F.3d 1022, 1028 (Fed. Cir. 2001); Harrell v. Commissioner, T.C. Memo. 2003-271 (remanding when a Supreme Court case decided after the notice of determination resolved a relevant question about equitable tolling). Petitioners'…
  10. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    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…
  11. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …lacks economic substance beyond the creation of tax benefits. Karr v. Commissioner , 924 F.2d 1018, 1022-1023 (11th Cir. 1991), affg. Smith v. Commissioner , 91 T.C. 733 (1988). In the context of a sale transaction, as here, the inquiry is whether the parties have in fact done what the form of their agreement purports …
  12. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    t additional tax if the distributions are, inter alia : (1) Made on or after the date o n which the employee attains the age of 59-1/2 ; (2) made to a beneficiary ( or to the estate of the employee ) on or after the death of the employee ; ( 3) attributable to the employee's being disabled within the meaning of section…
  13. 49 T.C. 419 — Gittens v. Commissioner
    IRCCourt RulingsJan 25, 1968
    …ack E. Schlegel, supra; Rybacki v. Conley, 340 F. 2d 944 (C.A. 2, 1965); Thomas E. Judkins, 31 T.C. 1022 (1959); but it has been seriously questioned by others, e.g., United States v. Johnson, supra; United States v. Martin, supra; E. N. Funkhouser, supra. The “separation from the service” criterion of section 402(a) (…
  14. 45 T.C. 168 — Lilly v. Commissioner
    IRCCourt RulingsNov 26, 1965related by meaning
    ired employee of the Civil Service Retirement Act, see Edward C. Heard, 40 T.C. 7, affd. 326 F. 2d 962 (C.A. 8, 1964), certiorari denied 377 U.S. 378. For reasons which will later appear, we need not take too seriously petitioner’s contention that the entire amount of $1,024.92 received during each of the taxable years…
  15. IRCCourt RulingsAug 3, 1979related by meaning
    155. Decisions will be entered for the respondent in docket Nos. 6173-77 and 11438-77. Decision will be entered under Rule 155 inI docket No. 9115-77. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954, as in effect for the taxable year in issue. Respondent concedes …
  16. T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip…
    IRCTreasury DecisionsNov 27, 2006related by meaning
    lans. * * * * * Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows: §1.7476-2 Notice to interested parties. * * * * * (c) * * * (2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of…
  17. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004related by meaning
    oyer whose employees are covered by the plan described in paragraph (1), or (ii) any authorized officer of the cooperative described in paragraph (1), consenting to the application of sections 4978 and 4979A with respect to such employer or cooperative. * * * * * * * (c) Definitions; Special Rules. * * * * * * * * * * …
  18. 37 T.C. 7 — Barbourville Brick Co. v. Commissioner
    IRCCourt RulingsOct 9, 1961related by meaning
    ar 1954 under the provisions of section 404(a)(5), and section 1.404(a)-12, Income Tax Regs. On brief, petitioner states the “Issue To Be Decided” as— Where the petitioner obligated itself to pay to the widow of its deceased President an amount equivalent to the monthly salary of the deceased President for a period of …