146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner IRCCourt RulingsMar 29, 2016
… IRAs
and caused the IRAs to establish and to wholly own a newly formed corporation.
S_e_e 4 at 218-220. The taxpayers then caused the corporation to purchase
(through AJH) the assets of a business by, among other things, receiving from the
seller a loan that the taxpayers personally guaranteed. See 4 at 217, 220-221.
…
IRCCourt RulingsNov 4, 1976related by meaning
loyment is for not more than 20 hours in any one week, and employees whose customary employment is for not more than 5 months in any calendar year, or (B) such employees as qualify under a classification set up by the employer and found by the Secretary or his delegate not to be discriminatory in favor of employees who…
IRCCourt RulingsDec 5, 2007
…r whole life policy had a
total death benefit of $ 596,009 .81, less an outstanding policy
loan of $220 , 206 .85, for a net death benefit of $ 375,802 .96 . As
of the same date, the Domingos survivor whole life policy had a
cash surrender value of $224 , 475 .17, less the outstanding policy
loan of $220 , 206 .85, for…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
IRCCourt RulingsFeb 15, 1979related by meaning
17 12,736.05 34 127 161
Calvin W. Wisinger ... 17 15,496.49 34 154 188
Jerry D. Hill . 18 15,306.55 36 153 189
John T. Novicki . 18 6,645.87 36 66 102 The record also indicates that the turnover rate for petitioner’s rank-and-file employees was 13.43, 19.74, 19.32, 7.06, and 21.16 percent in the respective years of 197…
IRCCourt RulingsAug 8, 2005related by meaning
the employee or the joint
lives (or joint life expectancies) of such
employee and his designated beneficiary,
(v) made to an employee after separation from service after attainment of age 55,
(vi) dividends paid with respect to
stock of a corporation which are described in
section 404(k), or
(vii) made on account of a …
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
ion under PTE 77-4. The Department requests comment on this proposed revocation, and also on how the remaining parts of PTE 75-1 Part II will be used. The Department is further proposing to revise the recordkeeping provisions of Section (e) of PTE 75-1, Part II. Section (e) currently provides that records demonstrating…
78 FR 8456 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCProposed Rules (FR)Proposed Feb 6, 2013
…ic Health Service Act (42 U.S.C. 300gg-41 through 300gg-63, 300gg-91, and 300gg-92).
4. Section 148.220 is amended as follows: a. In the introductory text of paragraph (b), the reference “(b)(6)” is removed and the reference “(b)(7)” is added in its place.
b. Adding paragraph (b)(7).
The addition reads as follows:
§ 14…
81 FR 21147 — Amendment to and Partial Revocation of Prohibited Transaction Exemption (PTE) 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Co… ERISAFinal Rules (FR)Apr 8, 2016related by meaning
nancial institution, an insurance company, or a broker-dealer.
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8.
Cerulli Associates, “Retirement Markets 2015.”
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9. The Department initially proposed an amendment to its regulation defining a fiduciary within the meaning of ERISA section 3(21)(A)(ii) and Code section 4975(e)(3)(B) on…
75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans ERISAProposed Rules (FR)Proposed Aug 30, 2010
…cent) will be mailed. The material cost associated with mailing the 4,397 SPEs at $.05 per page is $220. Therefore, the total cost burden for distribution of the notices and SPEs is estimated to be approximately $6,953 ($6,733 for the notices + $220 for the cost of including the SPEs).
Type of Review:
New collection.
A…
IRCCourt RulingsJul 22, 1980related by meaning
y for purposes of applying such section. * * *
Sec. 83(a) and (c)(1) states:
SEC. 83. PROPERTY TRANSFERRED IN CONNECTION WITH PERFORMANCE OF SERVICES. (a) General Rule. — If, in connection with the performance of services, property is transferred to any person other than the person for whom such services are performed,…
88 FR 87968 — Definition of “Employer”-Association Health Plans ERISAProposed Rules (FR)Proposed Dec 20, 2023
…lating Multiple Employer Welfare Arrangements.” March 1992, pg. 2-3 at
https://www.gao.gov/assets/220/215647.pdf.
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43.
83 FR 28912, 28928-29 (June 21, 2018).
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44.
Encino Motorcars, LLC
v.
Navarro,
579 U.S. 211, 220-23 (2016);
see id.
At 225 (Ginsburg, J., concurring) (restating the…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMay 4, 1978related by meaning
angery .93.16'
Miller’s .104.95
Franklin Optical .33.80
Lowenstein Bros .106.00
569.04
$39.95 to Lowenstein Bros.
$16.25 to Maxey’s Boat Dock for gas. $83.44 to Hub Clothiers for winter clothing.
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsJan 30, 2007related by meaning
led their return more than 25
months after it was due, the addition to tax under sec.
6651(a)(1) will be 25 percent of the amount required to be shown as a tax on the return. See sec. 6651(a)(1). The amount of the
addition to tax should be determined by the parties as part of
their Rule 155 computations.
IRCCourt RulingsFeb 9, 2023related by meaning
services is $100,000. Assume that
the district director proposes to increase D’s income by
$100,000, but that the country in which F is located would have blocked payment in 196 5 for such services. If, prior
to the first occurring of the events described in subdivisions
(i), (ii), or (iii) of this subparagraph, D ele…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023
…ceeds 10. Partnership X would be subject to a penalty of $55,000 for failing to electronically file 220 Schedules K-1 and K-3 required to be included with the partnership return: the 11th through the 230th of the required schedules ($250 × 220 = $55,000). See section 6698 for the penalty for the failure to file the par…
80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P… ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
40 FR 50845 (Oct. 31, 1975).
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13.
71 FR 5883 (Feb. 3, 2006).
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14.
69 FR 23216 (April 28, 2004).
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15. Although PTE 75-1, Part II, is silent on the payment of commissions, the commenters point to the preamble to the proposal of PTE 77-9 (41 FR 56760, December 29, 1976)(f…