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89 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    upplement to the Code of Federal Regulations was published in 1944. R. R egulations 111 In 1943, the Treasury Depart ment promulgated Regulations 111. Regulations 111 Relating to the Income Tax Under the Internal Revenue Code (Gov’t Prtg. Off. 1943). Like Regulations 103, Regulations 111 interpreted the provisions of t…
  2. IRCCourt RulingsOct 12, 1978related by meaning
    do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
  3. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992). In order to implement the views expressed herein, An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  5. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    egal professional. The labor rate is applied in the following calculation: (210 IRA × (15 minutes ÷ 60 minutes)) per IRA) × $159.34 per hour = $8,365. Back to Citation 548.  The burden is estimated as: (210 IRA × (5 minutes ÷ 60 minutes) per IRA) = 17.5 hours. A labor rate of $63.45 is used for a clerical worker. The l…
  6. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    T.C. Summary Opinion 2011-113 UNITED STATES TAX COURT GAIL MARIE WATSON, Petitioner v. COMMISSIONER- OF INTERNAL REVENUE, Respondent Docket No. 14769-10S. Filed September 28, 2011. Gail Marie Watson, pro se . . .. Ryan M. Wyzik, for respondent. . DAWSON, Judge: The petition' in this case was filed pursuant to the provi…
  7. 81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities
    IRCProposed Rules (FR)Proposed Apr 4, 2016
    …. 5318(h)(1)(A-D). Back to Citation 32.  31 U.S.C. 5312(a)(2)(G). Back to Citation 33.  31 CFR 1023.210. See also Notice of Proposed Rulemaking—Customer Due Diligence Requirements for Financial Institutions 79 FR 45151 (Aug. 4, 2014). Treasury proposed rules to clarify and strengthen customer due diligence requirements…
  8. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  9. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  10. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  11. 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…
  12. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …enalty per affected homeworker Minor Substantial Repeated, intentional or knowing Recordkeeping $21-210 $210-421 $421-1,052 Monetary violations 21-210 210-421 Employment of homeworkers without a certificate 210-421 421-1,052 Other violations of statutes, regulations or employer assurances 21-210 210-421 421-1,052 PART …
  13. Rev. Proc. 2015-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 2, 2015
    …an 209 .03 Timing of determination letter applications for adopting employers of pre-approved plans 210 SECTION 10. MULTIPLE EMPLOYER PLANS 210 .01 Scope 210 .02 Options to file for the plan only or for both the plan and employers maintaining the plan 210 .03 Where to file 210 .04 Determination letter sent to each empl…
  14. 88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …5 per page) + $0.66 for postage = $0.76; The mailing rate is applied in the following calculation: (210 authorizations for IRAs × 5.8 percent paper) × $0.76 = $9. Back to Citation 37.  The burden is estimated as follows: [[(75 plans × 5 minutes per plan) ÷ 60 minutes] + [(210 IRAs × 5 minutes per IRA) ÷ 60 minutes] = 2…
  15. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. (b) Retroactivity of R…
  16. 29 C.F.R. § 4043.23(f)(3)(i) — Active participant reduction.
    PBGCRegulationsJun 24, 2020
    …entage February 1 50 50 50/1,000 = 5 percent. May 15 50 100 100/1,000 = 10 percent. September 1 110 210 210/1,000 = 21 percent. November 1 40 250 250/1,000 = 25 percent. (f)(3)(ii) (ii) A single-cause event occurs on September 1 because that is the first time the applicable percentage exceeds 20 percent. This event mus…
  17. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …e 208 .02 Required forms 209 .03 Supplemental information 209 .04 Compliance with Title IV of ERISA 210 .05 Termination prior to time for amending for change in law 210 .06 Restatement not required for terminating plan 210 SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS? 210 .01 Scope 2…
  18. Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 4, 2016
    …4 applies 209 .07 Separate application required for each single § 414(l) plan 209 .08 Prior letters 210 .09 User fees 210 .10 Interested party notification and comment 210 .11 Contrary authority must be distinguished 210 .12 Employer/employee relationship 210 .13 Incomplete applications 210 .14 Effect of failure to dis…
  19. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted. An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
  20. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … applying a 3 percent discount rate. Back to Citation 235.  This is calculated 17,333/(1−0.25) = 23,111. Back to Citation 236.  The burden is estimated as follows: 23,111 claims × 2 hours + 23,111 claims × 0.25 hour = 51,999 hours. A labor rate of $105.01 is used for a medical and health services manager and a labor ra…