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96 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ble. Zmuda v. Commissioner , 79 T.C. 714, 727 (1982), affd. 731 F.2d 1417 (9th Cir. 1984). In this instance, petitioner readily admits that A Atlantic is presently holding his property, and that there is a - 9 - 7 For the purposes of sec. 72(t), the term "employee" also refers to participants in individual retirement a…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
  3. Notice 2009-98 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the…
    IRCNoticesDec 28, 2009
    …diness, Veterans’ Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007, Pub. L. 110-28, the Heroes Earnings Assistance and Relief Tax Act of 2008 (HEART Act), Pub. L. 110-245, the Emergency Economic Stabilization Act of 2008 (EESA), Pub. L. 110-343, and the Worker, Retiree, and Employer Recovery Act…
  4. REG-139236-07 — Proposed regulations under section 430 of the Code provide guidance on the valuation of plan assets and the determination of benefit liabilities for purposes o…
    IRCProposed Rules (FR)Proposed Mar 3, 2008
    …s and administrative expenses paid from plan assets during the same period. (iii) Restriction to 90-110 percent corridor—(A) Asset value less than 90 percent of fair market value. If the value of plan assets determined under paragraph (c)(2)(i) of this section is less than 90 percent of the fair market value of plan as…
  5. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    Federal income tax return on or before the payment due date unless such failure is due to reasonable cause and not due to willful neglect. The section 6651(a)(2) addition to tax applies only when an amount of tax is shown on a return filed by the taxpayer or prepared by the Secretary. Sec. 6651(a)(2), (g)(2); Cabirac v…
  6. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980related by meaning
    nstant case — to avoid the section 4973 excise tax. We hold that Johnson is liable for the asserted excise taxes under section 4973 for 1975 and 1976. It appears that the notice of deficiency addressed to petitioners may be understood as asserting joint liabilities for the excise tax deficiencies. (See n.l supra) Since…
  7. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    must decide whether the Court has jurisdiction to review respondent's whistleblower claim award determination where the claim is based on information the whistleblower provided both before and after the enactment of TRHCA sec. 406, 120 Stat. at 2958.9 ¹° I. Overview of the Court's Jurisdiction and the Whistleblower Pr…
  8. Treas. Reg. § 1.410(b)-6(b)(4) — Excludable employees.
    IRCRegulationsSep 9, 2016
    …ge and service is below the permissible minimums provided in section 410(b)(1)(A). The employer has 110 employees who either do not have 1 year of service or are not at least age 21. Of these 110 employees, 10 are highly compensated employees and 100 are nonhighly compensated employees. Five of these highly compensated…
  9. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    144 T.C. No. 9 UNITED STATES TAX COURT RALIM S. EL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19012-12. Filed March 12, 2015. R determined a deficiency in P's Federal income tax and additions to tax under I.R.C. sec. 6651(a)(1) and (2). Included in R's deficiency determination is additional …
  10. Treas. Reg. § 1.430(d)-1(g)(5)(ii)(B) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    …so that it is neither less than 90 percent of the fair market value of plan assets nor greater than 110 percent of the fair market value of plan assets on the valuation date for that plan year. If the value of plan assets prior to adjustment under this paragraph (g)(5)(ii)(B) is less than 90 percent of the fair market …
  11. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ddress the income tax consequences of the recharacterization of the DISC commissions. However, respondent's position that a transaction may be treated differently under different tax regimes seeds, on the surface, to have some support in 'cases which have held -that the income and gift tax statutes are not read in conj…
  12. 41 T.C. 685 — Conroy v. Commissioner
    IRCCourt RulingsFeb 26, 1964related by meaning
    It follows, therefore, that the amounts received by petitioners from the special fund are not excludable from gross income under either section 104 or section 105 unless they are covered by subsection 105(b), subsection 105(c), or subsection 105(d). Only the last subsection (105(d)), to which petitioners make no refere…
  13. Treas. Reg. § 54.4971(c)-1(g) — Taxes on failure to meet minimum funding standards; definitions.
    IRCRegulationsDec 30, 2016
    …r taxable year. The minimum required contributions for Plan C are $100,000 for the 2008 plan year, $110,000 for the 2009 plan year, $125,000 for the 2010 plan year, and $135,000 for the 2011 plan year. No contributions for these plan years are made until September 15, 2012, at which time the plan sponsor contributes $2…
  14. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    f this title, section 529 of title 81, or section 259 or 267 of title 40, and before approval of title to the underlying land by the Attorney General. There seem to be discrepancies in the figures stipulated by the parties, used by petitioner in reporting income on its tax returns, and employed by the parties on brief.…
  15. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    IRCCourt RulingsJul 25, 2005related by meaning
    he specific restrictions contained in section 72(t)(2). See, e.g., Clark v. Commissioner , 101 T.C. 215, 224-225 (1993); Vorwald v. - 6 - Commissioner , T.C. Memo. 1997-15. General financial or emotional hardship is not an exception from the section 72(t) additional tax on early retirement plan distributions. Milner v.…
  16. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …, 1996. Back to Citation 23.  Public Law 104-204 (Sept. 26, 1996). Back to Citation 24.  Public Law 110-343 (Oct. 3, 2008). Back to Citation 25.  Public Law 104-204 (Sept. 26, 1996). Back to Citation 26.  Public Law 105-277 (Oct. 21, 1998). Back to Citation 27.  Public Law 110-233 (May 21, 2008). Back to Citation 28.  …
  17. T.C. Summary Opinion 2017-64 — Wilfred Omoloh v. Commissioner
    IRCCourt RulingsAug 16, 2017related by meaning
    en of proving that those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290 U.S. I11, 115 (1933). I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a qualified retirement plan equal to 10% of the portion of the amount that is includable in gros…
  18. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …26, 1996). Back to Citation 4.  Public Law 105-277 (Oct. 21, 1998). Back to Citation 5.  Public Law 110-233 (May 21, 2008). Back to Citation 6.  Public Law 110-343 (Oct. 3, 2008). Back to Citation 7.  Public Law 111-3 (Feb. 4, 2009). Back to Citation 8.  Public Law 110-381 (Oct. 9, 2008). Back to Citation 9.  Public La…
  19. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    Notice 95-34 the IRS provided guidance on the tax problems raised by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there was not substan…
  20. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026
    …6 Period for Compounding Annual Semiannual Quarterly Monthly Short-term AFR 3.85% 3.81% 3.79% 3.78% 110% AFR 4.23% 4.19% 4.17% 4.15% 120% AFR 4.62% 4.57% 4.54% 4.53% 130% AFR 5.01% 4.95% 4.92% 4.90% Mid-term AFR 4.13% 4.09% 4.07% 4.06% 110% AFR 4.55% 4.50% 4.47% 4.46% 120% AFR 4.97% 4.91% 4.88% 4.86% 130% AFR 5.39% 5.3…