PBGCCode / StatuteJan 6, 2025related by meaning
(c) (c) Repealed. Pub. L. 112–141, div. D, title II, §40234(a), July 6, 2012, 126 Stat. 858
IRCCourt RulingsJan 28, 2014
…4] individual retirement accounts only once every three years.");6 H.R. Conf.
Rept. No. 93-1280, at 342 (1974), 1974-3 C.B. 415, 503 ("Tax-free rollovers
between individual retirement accounts may occur only once every three years.").
As we previously noted, section 408(d)(3)(B) applies a one-year waiting
PBGCCode / StatuteJan 6, 2017related by meaning
(b) (b) Amendment respecting methods for computing withdrawal liability An amendment permitted by section 1391(c)(5) of this title may be adopted only in accordance with that section.
IRCCourt RulingsOct 4, 2012
…presumably incorporates that meaning when it uses
the term. See, e.g., Morissette v. United States, 342 U.S. 246, 263 (1952). We
disagree, however, that the phrase "investment in the contract" is an established
term of art.
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While section 72 def'mes the phrase "investment in the contract," nowhere
in that section…
IRCCourt RulingsNov 3, 2008
…) unemployment compensation
from the Commonwealth of Pennsylvania of $3,429 and tax
withholding of $342, reported to respondent on Form 1099-G, .
Certain Government Payments ; and (3) the 10-percent additional
tax of $1,625 under section 72( ;t) for a premature distribution
ERISACode / StatuteJan 24, 2020related by meaning
(c) (c) Individual statement furnished by administrator to participants setting forth information in administrator's Internal Revenue registration statement and notification of forfeitable benefits Each administrator required to register under section 6057 of title 26 shall, before the expiration of the time prescribed…
IRCCourt RulingsApr 14, 2005
…l of the work environment to control the employee. Gen.
Inv. Corp. v. United States
, 823 F.2d 337, 342 (9th Cir. 1987).
Mr. Urman was the COR to whom petitioner was directly
responsible. Mr. Urman assigned projects to petitioner, provided
policy guidance, and established general priorities. Mr. Urman
could not, howeve…
ERISACode / StatuteJan 6, 2025related by meaning
(a) (a) Named fiduciaries
(a)(1) (1) Every employee benefit plan shall be established and maintained pursuant to a written instrument. Such instrument shall provide for one or more named fiduciaries who jointly or severally shall have authority to control and manage the operation and administration of the plan.
(a)(2) …
109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner IRCCourt RulingsDec 29, 1997
… him for his
[purposes]" quoting C.G. Willis, Inc. v. Commissioner
, 41 T.C.
468, 476 (1964), affd. 342 F.2d 996 (3d Cir. 1965), which
involved nonrecognition of gain upon an involuntary conversion
under section 1033. Petitioner also quotes a similar definition
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of an involuntary conversion in Grant Oil Tool Co. …
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996
…d. Mich. Comp. Laws Ann. sec. 450.1833 (West 1970); cf.
United States v. Adams Bldg. Co.
, 531 F.2d 342 (6th Cir. 1976).
However, upon the P.C.'s dissolution, the Board of Directors
(i.e., Mr. Souris) resolved that Mr. Souris would be the
successor plan sponsor of the P.C.'s "Employees' Pension Plan".
Moreover, as indi…
IRCCourt RulingsAug 16, 2005
… F.3d 275, 278 (4th Cir. 1999), affg. T.C. Memo. 1996-452;
Charlton v. Commissioner
, 114 T.C. 333, 342 (2000); Rowe v.
Commissioner
, T.C. Memo. 2001-325. The allocation, however, is
not permitted if the Secretary shows by a preponderance of the
evidence that the electing individual had “actual knowledge, at
the time …
ERISACode / StatuteJan 6, 2017related by meaning
may seek assistance or information regarding their rights under this chapter and the Health Insurance Portability and Accountability Act of 1996 with respect to health benefits that are offered through a group health plan (as defined in section 1191b(a)(1) of this title), the remedies available under the plan for the r…
IRCCourt RulingsMar 14, 2005
…spondent determined a deficiency in petitioners’ Federal
income tax for the taxable year 2001 of $1,342.
The issue for decision is whether a distribution of $8,944
resulting from the surrender of a life insurance policy is
includable in petitioners’ gross income. We hold that it is.
Background
Some of the facts have be…
ERISARegulationsJan 1, 2017related by meaning
Section 502(l) of the Employee Retirement Income Security Act of 1974 (ERISA or the Act) requires the Secretary of Labor to assess a civil penalty against a fiduciary who breaches a fiduciary responsibility under, or commits any other violation of, part 4 of title I of ERISA or any other person who knowingly participat…
T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner IRCCourt RulingsApr 27, 1998
…rary administrator is not an agent of the estate. See
Maryland Cas. Co. v. United States
, 251 U.S. 342, 346-347 (1920);
Wilson v. Commissioner
, 12 B.T.A. 403, 405 (1928) ("It is a well
established principle of law that receipt by an agent is receipt
by the principal.").
Before a 1993 change in New York law which broa…
IRCCourt RulingsFeb 6, 2012
…isfy the
conditions of section 162 or section 212".6 S. Rept. No. 87-992, supra, 1962-3
C.B. at 341-342; see sec. 404(a)(8). Further, 1962 Act sec. 7, 76 Stat. at 828,
amended section 62 to provide that self-employed individuals were entitled to the
deduction from gross income allowed by section 404. S. Rept. No. 87-99…
ERISACode / StatuteJan 5, 2015related by meaning
§§1085b, 1086. Repealed. Pub. L. 109–280, title I, §101(a), Aug. 17, 2006, 120 Stat. 784
IRCCourt RulingsMay 15, 2003
…g continued institutionalization or constant supervision. See Dwyer v. Commissioner
, 106 T.C.
337, 342 (1996) (The taxpayer suffered from severe depression for
which he had periodic consultations with a psychologist; the
Court held that periodic professional consultation alone does not
equate with the constant supervi…
ERISACode / StatuteJan 6, 2025related by meaning
(b)(20)(E)(iii)(II) (II) to restore to the plan or affected account any profits made through the use of assets of the plan.
(b)(21) (21) The provision of a de minimis financial incentive described in section 401(k)(4)(A) or section 403(b)(12)(A) of title 26.
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
…described the antialientation procedures under the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, 88 Stat.
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[*14] 829, 29 U.S.C. sec. 1001 (2006), and the Internal Revenue Code in Gallade
v. Commissioner, 106 T.C. 355, 361 (1996), as follows:
ERISA was enacted to establish "a compreh…