91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…n (RFI) to begin developing a public record for several provisions of SECURE 2.0, including section 338.[7]
The RFI asked three questions (19-21) to gather input on options for implementing section 338 of SECURE 2.0. Several ideas and suggestions submitted were well beyond the scope of the directive in section 338. Oth…
Notice 2020-86 — Guidance on Sections 102 and 103 of the SECURE Act With Respect to Safe Harbor Plans IRCNoticesModified Dec 28, 2020
…86
I. PURPOSE
This notice provides guidance in the form of questions and answers with respect to §§ 102 and 103 of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act).1 Section…
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…
0.5
193.15
2,084,668
−2,084,668 Primary Assumption
21,586
1
193.15
4,169,336
0
21,586
2
193.15
8,338,672
4,169,336
21,586
3
193.15
12,508,008
8,338,672
3. Initial Notice of Default E-Delivery and Right to Opt Out:
A. Compensation and Benefits Manager prepares initial notice of default e-delivery and right to opt o…
IRCCourt RulingsSep 25, 1996
…984
- 26 -
note was for $285,942, Machise had earlier "advanced"
$6,509 and issued a check for $150,338, for a total of
$442,789.) After 1986, the notes were issued by MPC.
8. The demand notes (and the check for $150,338) are
deemed distributed to the MIT 80 partners.
9. Endorsements reflect that the demand notes (and …
88 FR 54511 — Request for Information-SECURE 2.0 Reporting and Disclosure ERISAProposed Rules (FR)Proposed Aug 11, 2023
…
Question 19: What modifications or updates to the 2002 safe harbor are needed to implement section 338 of SECURE 2.0? Commenters are encouraged to consider whether any additional information (other than a statement of the right to request that all documents required to be disclosed under ERISA be furnished on paper in…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCRegulationsJul 26, 2016
….3 95 100 1.9 1.9 1.8 1.7 1.6 1.6 1.5 1.4 1.3 1.2 96 101 1.8 1.7 1.7 1.6 1.5 1.5 1.4 1.3 1.2 1.1 97 102 1.7 1.6 1.6 1.5 1.4 1.4 1.3 1.2 1.1 1.1 98 103 1.6 1.5 1.4 1.4 1.3 1.3 1.2 1.1 1.0 1.0 99 104 1.4 1.4 1.3 1.3 1.2 1.1 1.1 1.0 1.0 0.9 Male Female Ages Male 97 98 99 100 101 102 103 104 105 106 Female 102 103 104 105 …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
29 C.F.R. § 2520.104b-4(a)(3)(ii) — Alternative methods of compliance for furnishing the summary plan description and summaries of material modifications of a pension plan to a retired participan… ERISARegulationsJan 1, 2017
…ction if the document omitted only information described in one or more of the provisions of § 2520.102-3 listed below, provided that a supplement containing such information, which meets the requirements of § 2520.102-2, is furnished to the retired participant, vested separated participant, or beneficiary receiving be…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsJun 6, 2005related by meaning
a matter of
legislative grace, and the burden of clearly showing the right to
the claimed deduction is on the taxpayer. INDOPCO, Inc. v.
Commissioner , 503 U.S. 79, 84 (1992). We are bound by the
Internal Revenue Code, and it is within the province of the
legislature to decide the circumstances of inclusion, deductions…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
81 FR 40569 — Application of Section 409A to Nonqualified Deferred Compensation Plans IRCProposed Rules (FR)Proposed Jun 22, 2016
…rule may be used with respect to a transaction that is treated as a deemed asset sale under section 338. The provision of the final regulations giving buyers and sellers in asset transactions the discretion to treat employees as separating from service is based on the recognition that, while employees formally terminat…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…COVERED BY AUTOMATIC APPROVAL PROCEDURES IN WHICH RULINGS WILL NOT ORDINARILY BE ISSUED
.01 Section 338.—Certain Stock Purchases Treated as Asset Acquisitions.—All requests for an extension of time under § 301.9100-3 within which to make an election under § 338(g) or (h)(10) where the Service has provided an administra…