IRCCourt RulingsJun 4, 2014related by meaning
ication of a
pending or planned examination or investigation as a result of information
provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010). Additionally, the Tax Court has exclusive jurisdiction over appeals of award
determinations where a whistleblower provided information both before and after
the effectiv…
IRCCourt RulingsMay 23, 1979related by meaning
rden of proof on the unreasonable compensation issue since he raised it in his amended answer. Rule 142(a), Tax Court Rules of Practice and Procedure. Turning to the merits, we note that respondent argues that the case of Bianchi v. Commissioner, 66 T.C. 324 (1976), affd. per curiam 553 F.2d 93 (2d Cir. 1977), is direc…
89 FR 43675 — Prohibited Transaction Exemption 2006-06 for Services Provided in Connection With the Termination of Abandoned Individual Account Plans ERISAFinal Rules (FR)May 17, 2024related by meaning
section 4975(c)(2) necessitate proposing an amendment to the exemption.
Back to Citation
26.
See 29 CFR 2578.1(d)(2)(v).
Back to Citation
27.
See Section I(a)(3) of this exemption amendment.
Back to Citation
28.
See
paragraph 29 CFR 2578.1(c)(3) of the QTA Regulation or in the case of a QTA described in Section …
PBGCProposed Rules (FR)Proposed Aug 18, 2023
…The authority citation for part 4050 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1350.
16. Amend § 4050.102 by revising paragraphs (2), (4), and (7)(i) of the definition of “ PBGC missing participants assumptions”
to read as follows:
§ 4050.102
Definitions.
* * * * *
( printed page 56579)
PBGC missin…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
85 FR 6046 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Feb 4, 2020
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
14. Revise § 4041.29 to read as follows:
§ 4041.29
Post-distribution certification.
(a)
Filing requirement.
The plan administrator must either—
( printed page 6061)
(1) Within 30 days after the last distribution da…
83 FR 9716 — Owner-Participant Changes to Guaranteed Benefits and Asset Allocation PBGCProposed Rules (FR)Proposed Mar 7, 2018
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
§ 4041.2
[Amended]
11. In § 4041.2:
a. Amend the introductory text by removing the words “mandatory employee contributions” and adding in their place the words “majority owner, mandatory employee contributions”; an…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
PBGCFinal Rules (FR)May 13, 2016
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
§ 4041.6
[Amended]
4. In § 4041.6, the words “of up to $1,100 a day for each day that the failure continues” are removed.
PART 4071—PENALTIES FOR FAILURE TO PROVIDE CERTAIN NOTICES OR OTHER MATERIAL INFORMATION
5. …
IRCCourt RulingsNov 4, 1998related by meaning
laration shall have the force and effect of a
decision of the Tax Court and shall be reviewable as
such. For purposes of this section, a determination with respect to a continuing qualification includes any
revocation of or other change in a qualification.
(b) Limitations.--
(1) Petitioner.--A pleading may be filed und…
IRCCourt RulingsMar 20, 1997related by meaning
but did not." Central Tablet Manufacturing
Co. v. United States
, 417 U.S. 673, 690 (1974); Commissioner v.
National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149
(1974). It would be quite intolerable to pyramid the existing
complexities of tax law by a rule that the tax shall be that
resulting from the for…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
76 FR 67105 — Cash Balance Plans; Benefit Determinations and Plan Valuations for Statutory Hybrid Plans; Pension Protection Act of 2006 PBGCProposed Rules (FR)Proposed Oct 31, 2011
…y citation for part 4041 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1341, 1344, 1350.
7. In § 4041.2, amend the first paragraph by removing the words “standard termination, termination date” and adding in their place “standard termination, statutory hybrid plan, termination date”.
8. In § 4041.28, a…
IRCCourt RulingsFeb 6, 1992
…p. v. Commissioner, 89 T.C. 765 (1987); Zinniel v. Commissioner, 89 T.C. 357 (1987), affd. 883 F.2d 1350 (7th Cir. 1989). The temporary regulation in question is an interpretive one promulgated under the Secretary's general rule-making power under section 7805(a). “The role of the judiciary in cases of this sort begins…
IRCCourt RulingsNov 17, 2016related by meaning
etitioner neglected to apply the correct method to reduce the maximum
benefits under section 415(b)(2)(C) for a retirement age before age 62 under its plan, where the plan did not provide for forfeiture of the participant's benefits at
death. By virtue of this error, portions of petitioner's contributions to the plan
d…