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97 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 110 T.C. No. 22 — Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner
    IRCCourt RulingsApr 27, 1998related by meaning
    w why the statute as enacted contains language different from that in the House and - 10 - 1 We have been unable to find any other section of the Code that uses this phrase. Other sections of the Code that authorize this Court to grant a declaratory judgment include secs. 6234, 7428, 7477, 7478, and 7479. 2 Sec. 7503 a…
  2. 78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Mar 21, 2013
    … employees. Back to Citation 26.  1,200 hours/40 hours per week = 30 weeks; 30 weeks *7 days/week = 210 days; 210 days eligibility requirement + 90 day wait period = 300 days. Back to Citation 27.  Under ERISA section 104(a)(2), the Secretary may also provide exemptions or simplified reporting and disclosure requiremen…
  3. 76 T.C. 861; 2 Employee Benefits Cas. (BNA) 1450 — Estate of Perl v. Commissioner
    IRCCourt RulingsMay 27, 1981related by meaning
    n reaching our decision. All section references are to the Internal Revenue Code of 1954 as amended and in effect in the year of the decedent’s death. Petitioner also argues that sec. 2039(e), dealing with Individual Retirement Accounts (IRA), is applicable. That argument is plainly without merit, not only because by n…
  4. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …'s equity and basis pools. Branch's equity pool was equal to €200, and its basis pool was equal to $210, as shown below: Table 2 to Paragraph ( l )(1)( i )(D)—Year 3 Equity and Basis Pools   Equity pool Translation rate Basis pool Contribution (9/30/Year 1) €150 €1 = $1 $150 Year 2 Earnings €25 €1 = $1.15 28.75 Year 3 …
  5. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
  6. 88 FR 11984 — Annual Information Return/Reports
    IRCFinal Rules (FR)Feb 24, 2023
    that currently meet the definition of a MEP under ERISA section 210(a), including any PEPs, for plan years beginning on or after January 1, 2021.[18] With respect to a PEP, section 103(g) further requires that the annual return/report must include the identifying information for the person designated under the terms o…
  7. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    s. 601.201(a)(2) and (3), 601.201(1)(5), and 601.201(m), Statement of Procedural Rules; Myron v. United States, 382 F.Supp. 590, 597 (C.D. Cal. 1974). In analogous situations, when there have been similar material changes in the facts on which a ruling was based, the courts have upheld the Commissioner’s authority to r…
  8. 86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement
    IRCProposed Rules (FR)Proposed Sep 16, 2021
    …C—Transparency and Reporting Requirements for the Group and Individual Health Insurance Markets 149.210—149.220 [Reserved] 149.230 Reporting requirements regarding air ambulance services for plans and issuers. §§ 149.210-149.220 [Reserved] § 149.230 Reporting requirements regarding air ambulance services for plans and …
  9. 40 T.C. 882 — New York Post Corp. v. Commissioner
    IRCCourt RulingsAug 26, 1963related by meaning
    ly” or “primarily,” petitioner’s plan involved neither “solely” nor “primarily” a dismissal wage so as to remove it from the operation of section 404. Both versions of the regulations recognize that there are certain types of payments to employees that are not to be regarded as deferred compensation within the meaning …
  10. 93 T.C. 79; 93 T.C. No. 8 — McManus v. Commissioner
    IRCCourt RulingsJul 24, 1989related by meaning
    ans. Sec. 7476(a). There are two limitations on this Court’s authority which are relevant to the present case. They are contained in section 7476(b):] (3) Exhaustion of administrative remedies.— The Tax Court shall not issue a declaratory judgment or decree under this section in any proceeding unless it determines that…
  11. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    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 …
  12. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994related by meaning
    annot justify disregard of what Congress has plainly and intentionally provided. * * * [Commissioner v. Asphalt Prods. Co., 482 U.S. 117, 121 (1987).] See also Griffin v. Oceanic Contractors, Inc., 458 U.S. 564, 571 (1982); United States v. Mansfield Tire & Rubber Co., 942 F.2d 1055, 1058 (6th Cir. 1991). Here, we do n…
  13. 71 T.C. 332 — Brownholtz v. Commissioner
    IRCCourt RulingsDec 4, 1978related by meaning
    sion system or other plan providing post-employment benefits, and not as wages or in lieu of wages. See Jones v. Commissioner, 71 T.C. 128 (1978); cf. H. Rept. 1337, 83d Cong., 2d Sess. 10 (1954); S. Rept. 1622, 83d Cong., 2d Sess. 11 (1954). Thus, in granting the employee the option of taking the greater of the sectio…
  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
    tion 45.  15 U.S.C. 80b-11(g)(1). Back to Citation 46.   See e.g., Fish v. GreatBanc Trust Company, 749 F.3d 671 (7th Cir. 2014). Back to Citation 47.  As a practical matter, one way for financial institutions to ensure that they can meet this burden is by implementing strong anti-conflict policies and procedures, and …
  15. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
  16. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  17. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…