85 FR 40834 — Improving Investment Advice for Workers & Retirees ERISAProposed Rules (FR)Proposed Jul 7, 2020
…d exemption.
Broker-Dealers (BDs)
As of December 2018, there were 3,764 registered BDs. Of those, 2,766, or approximately 73.5 percent, reported retail customer activities,[78]
IRCCourt RulingsJul 29, 1997related by meaning
one taxable year; at
best, petitioner's assertion undermines the characterization of
the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case.
c. Frozen Deposit Rule
Finally, although it is not clear whether petitioner relies
on the special rule for frozen deposits f…
IRCCourt RulingsMar 5, 2018
… $4,889 $1,100 $1,222
2003 6,148 1,383 1,537
2004 6,372 1,433 (¹)
2005 6,817 1,533 (¹)
2006 7,850 1,766 (¹)
2007 8,616 1,938 (¹)
¹Amounts to be determined.
While residing in California, petitioners timely petitioned this Court with
respect to both notices of deficiency. These cases have been consolidated for trial,
bri…
IRCCourt RulingsMay 20, 2009related by meaning
flimited by sec . 72(p)(2)(A) to one .-
half of his retirement account balance .
1,
applies,,in this case . Petitioner is subject to the section 72(t) additional tax .
To ; reflect our disposition of the issues ,
Decision will be entere d
it,
for respondent .
r
IRCCourt RulingsNov 8, 1976related by meaning
n changing its name.
Decision will be entered for the respondent in docket No. 6797-74.
Decision will be entered under Rule 155 in docket No. 6798-74. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
Mr. Hebert is excluded from the computation because his salary …
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
e distribution.
Although section 816 of the 1954 Code rather than section 115 of the 1939 Code is applicable here, the relevant language is identical. The dividend issue was raised expressly by respondent for the first time at the trial by the statement that “the amounts involved in this case are * * * a preferential o…
IRCCourt RulingsApr 12, 1979
…ermining the 15-percent limitation for petitioner’s contribution deduction. The four employees had $766.62 allocated to their accounts. Robert McNair, R. Acosta, and Carole Castleberry forfeited to the remaining participants the amounts allocated to their accounts. Duane Fisher was a 10-percent vested participant and r…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsMar 28, 1994
…h, the taxpayer must execute the return under penalties of perjury. [Beard v. Commissioner, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th Cir. 1986).]
Petitioners argue that these statute of limitations cases are significant because, in the Beard case, we said that returns that are considered to be sufficient to tri…
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…2,000
26,555,000
2018
4,611,000
14,349,000
5,100,000
759,000
24,818,000 2019
4,309,000
13,410,000
4,766,000
709,000
23,194,000
2020
4,027,000
12,533,000
4,454,000
663,000
21,677,000
Total with 7% Discounting
412,183,000
Total with 3% Discounting
462,827,000
Note:
The displayed numbers are rounded to the nearest thousan…
IRCCourt RulingsFeb 6, 1992related by meaning
tioner had 34 employees on January 31, 1986, but paid bonuses to only 33 employees because one employee left the company prior to the date of payment. Petitioner filed a timely U.S. Corporation Income Tax Return (Form 1120) for its taxable year ended January 31, 1986, on July 28, 1986. S.B. Hoover & Co. of Harrisonburg…
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…
89 FR 5624 — Automatic Portability Transaction Regulations ERISAProposed Rules (FR)Proposed Jan 29, 2024
…,840
902,662
915,665
928,731
928,731
8,329,456
AP Transfers
397,749
519,606
630,585
699,159
724,418
766,494
809,360
817,864
839,779
824,156
7,029,170
Differences between the Baseline and Post-Rule:
Default IRAs
144,664
166,262
184,775
197,117
203,288
209,459
215,630
218,715
221,801
221,801
1,983,512
Accounts with AP
94…
IRCCourt RulingsMay 4, 2004related by meaning
ed to respondent under sec.
7491. In any event, we do not decide the issue in this case on
the burden of proof. Also, regardless of whether the $5,555 additional tax under sec. 72(t) would be considered an
“additional amount” under sec. 7491(c) and regardless of whether
the burden
of
production
with respect to this add…
IRCCourt RulingsSep 30, 2004related by meaning
etitioner did not
“roll over” her distributions pursuant to section 408(d)(3).
- 6 -
Therefore, in order for petitioner to prevail, she must show that the distributions fall under one of the exceptions under section
72(t)(2).
With respect to section 72(t), this Court has repeatedly
held that it is bound by the list of …
85 FR 82798 — Prohibited Transaction Exemption 2020-02, Improving Investment Advice for Workers & Retirees ERISAFinal Rules (FR)Dec 18, 2020
…nt entities.
Broker-Dealers (BDs)
As of December 2018, there were 3,764 registered BDs. Of those, 2,766, or approximately 73.5 percent, reported retail customer activities, while 998 were estimated to have no retail customers.[154]
The Department does not have information about how many BDs provide investment advice to…
IRCCourt RulingsOct 9, 2007related by meaning
ers . In response to
our leniency, petitioner once again ignored our Rules and our
order .
-5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a
sanction pursuant to Rule 123(b) . See Stringer v . Commissioner ,
84 T .C . 693, 704-705 (1985), affd . withou…
IRCCourt RulingsSep 24, 2007related by meaning
him . On May 24, 2002,
SBC Communications, Inc ., issued a check to petitioner in the
amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and
$3,367 .11 in California State income tax had been withheld .
During 2002, petitioner also received $9,552 …