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91 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. 75 FR 74622 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 1, 2010
    …ter than— From— To— 2012 568 568 2,400 2,400 2013 579 579 2,448 2,448 2014 591 591 2,497 2,497 2015 602 602 2,547 2,547 2016 614 614 2,598 2,598 2017 627 627 2,652 2,652 2018 640 640 2,708 2,708 2019 654 654 2,765 2,765 2020 668 668 2,823 2,823 2021 or later 682 682 2,882 2,882 1  Table II-A. 2  Table II-B. 3  Table II…
  2. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    …amount of tax shown on a return. A substitute for return prepared by the Commissioner under section 6020(b) is treated as a return filed by the taxpayer for purposes of section 6651(a)(2). Sec. 6651(g)(2); see also, e.g., Wheeler v. Commissioner, 127 T.C. 200, 208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). Resp…
  3. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  4. Rev. Proc. 2017-56 — This revenue procedure updates Rev. Proc. 2000–40 to take into account the provisions of § 430 of the Internal Revenue Code, which was enacted as part of the P…
    IRCRevenue ProceduresOct 30, 2017
    …uired contribution for Plan A for the plan year from January 1, 2018, to December 31, 2018, is $540,602. This is the total of the target normal cost of $285,000 (the total of the target normal cost for Plan A disregarding the merger of $200,000 and the target normal cost attributable to Plan B for the interim period of…
  5. T.D. 9783 — These final regulations change the regulations regarding the minimum present value requirements for defined benefit plan distributions to permit plans to simpl…
    IRCTreasury DecisionsSep 26, 2016
    …egment rates, the deferred annuity factor at age 55 for lifetime payments commencing at age 65 is 7.602. (ii) Plan D provides for a single-sum distribution of a portion of the participant’s accrued benefit but, because the plan initially specifies the amount of the single-sum distribution (rather than the portion of th…
  6. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respond…
  7. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
  8. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012related by meaning
    ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68 (3d Cir…
  9. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    tion that petitioners are liable for the 10-percent additional tax imposed by section 72(t). Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph (1), which imposes the tax, provides in relevant part as follows: (1) Imposition of Additional Tax.--If an…
  10. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    _ requirements under section 6020(b) Wheeler v. Commissioner, 127 T.C. 200 208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). A return made by the Secretary under section 6020(b) is'treated as the return filed by the taxpayer for purposes of section 6651(a)(2). Sec. 6651(g)(2). Respondent'satisfied his burden by in…
  11. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    5). 28See, e.g., Priv. Ltr. Rul. 201535029 (Aug. 28, 2015) (waiver granted to taxpayer suffering from "mild cognitive impairment and moderate clinical depression", who was "not aware that he did not roll over Amount 1 to another IRA until his tax return for 2013 was being prepared"); Priv. Ltr. Rul. 201323044 (June 7, …
  12. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  13. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    United States Tax Court T.C. Memo. 2022-69 CLAIR R. COUT URIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed July 6, 2022. ————— Alvah Lavar Taylor and Daniel W. Soto , for petitioner. Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and Edward T.…
  14. Treas. Reg. § 1.411(b)(5)-1(b)(2)(iii)(B) — Reduction in rate of benefit accrual under a defined benefit plan.
    IRCRegulationsSep 17, 2024
    …tat. 829 (1974)), and the Age Discrimination in Employment Act of 1967, Public Law 90-202 (81 Stat. 602 (1967)). (b)(4) (4) Permitted disparities in plan contributions or benefits. A plan is not treated as failing to meet the requirements of section 411(b)(1)(H) solely because the plan provides a disparity in contribut…
  15. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  16. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    that she assured him that respondent would “abate” the section 72(t) additional tax if petitioners immediately paid the deficiency shown in the March 31, 1999, letter. Petitioner was unaware of the extent of Ms. Flanagan’s authority to compromise their tax liability, and petitioners never received any correspondence f…
  17. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    OPINION Wright, Judge: Respondent determined a deficiency in petitioner’s Federal income tax for taxable year 1990 in the amount of $239,463. After concessions by the parties, the issues for our consideration are as follows: (1) Whether dividends paid to an employee stock ownership plan, deductible under section 404(k)…
  18. 29 C.F.R. § 2510.3-102(f)(3) — Definition of “plan assets”—participant contributions.
    ERISARegulationsJan 1, 2017
    …90 participants. Several former employees have elected, pursuant to the provisions of ERISA section 602, 29 U.S.C. 1162, to pay C for continuation of their coverage under the plan. These checks arrive at various times during the month and are deposited in the employer's general account at bank Z. Under paragraphs (a) a…
  19. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    tions and are administered in a manner identical to the manner in which the payments to article III judges in regular active service are administered. Accordingly, petitioners are not here receiving the double tax benefit Congress sought to prevent by section 219(b)(2)(A). Having decided that petitioners are entitled t…
  20. 29 C.F.R. § 4907.103(4) — Definitions.
    PBGCRegulationsJan 1, 2017
    …habilitation, Comprehensive Services, and Developmental Disabilities Amendments of 1978 (Pub. L. 95-602, 92 Stat. 2955). As used in this part, section 504 applies only to programs or activities conducted by Executive agencies and not to federally assisted programs. Substantial impairment means a significant loss of the…