PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsSep 22, 1998related by meaning
ural guidance provided by notices
or announcements. Rev. Rul. 90-91, 1990-2 C.B. 262.
nontaxable return of contributions.
8
A portion of the remaining balance of $504.36 is an amount of net income attributable to the
contributions for the 1992 taxable year. See sec. 408(d)(4);
sec. 1.408-4(c)(2)(ii) and (iii), Income T…
T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner IRCCourt RulingsApr 22, 1998
…ealable to the Court of Appeals
for the Ninth Circuit. See Koppen v. Commissioner
, T.C. Memo.
1995-316; Erickson v. Commissioner
, T.C. Memo. 1991-97; Coldiron
v. Commissioner
, T.C. Memo. 1987-569. In the absence of a clear
mandate from the Court of Appeals for the Ninth Circuit, we are
not compelled to hold the duty…
IRCCourt RulingsSep 25, 2000related by meaning
lity for the excise
taxes and that petitioner was liable for the additions to tax
under section 6651(a)(1).
Discussion
I. Liability Under Section 4975 A. The Statutes
Section 4975 was added to the Internal Revenue Code by title
II of the Employee Retirement Income Security Act of 1974
(ERISA), Pub. L. 93-406, sec. 2003…
IRCCourt RulingsDec 11, 1997
… of $194,118. Included in the computation of that loss was a
claimed long-term capital loss of $289,316 (claimed 1992 worthless stock loss) that petitioners explained in a statement
attached to their 1992 return as follows: "The National Bank of
Harrah Common Stock was evaluated in June, 1992 and determined to
be worth…
ERISACourt RulingsNov 18, 1994related by meaning
cy, it is applicable to all
enforcement actions which the DOL may bring after the date of
adoption, even if it is based, as this one is, on violations prior to 1992. Indeed, the stated purpose of T.R. 92-01 was to
expand the categories of violations as to which the DOL would not
assert a violation beyond the limited ca…
IRCCourt RulingsJul 15, 1997
…corporation as follows:
Taxable Year
Original Return
Amended Return
1986 $446,781 $253,167
1987 344,316 no amended return filed
1988 430,002 no amended return filed
During 1988, petitioner sold a rental building in Yorkville,
Illinois (the Yorkville building). Petitioner was personally
liable for a loan secured by the …
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
nd beneficiaries of the Plan and IRA owners; (3) If granted, the proposed exemption is applicable to a particular transaction only if the transaction satisfies the conditions specified in the exemption; and (4) The proposed exemption, if granted, is supplemental to, and not in derogation of, any other provisions of ERI…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
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