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72 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Notice 2010-80 — This notice provides additional relief for nonqualified deferred compensation plans covered under section 409A. This notice also expands the types of plans eli…
    IRCNoticesDec 20, 2010
    …d Employee SS treat the commencement of payment in 2011 as an operational failure under Notice 2008-113, and such failure is eligible to be corrected, and is actually corrected as an impermissible payment in accordance with Notice 2008-113, Employee SS is not required to include any amount in income under § 409A(a) sol…
  2. 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…
  3. 88 FR 54511 — Request for Information-SECURE 2.0 Reporting and Disclosure
    ERISAProposed Rules (FR)Proposed Aug 11, 2023
    E 2.0 requires the Department to issue regulations implementing the requirements under section 113 of ERISA not earlier than one year after enactment. Further, these regulations must contain a model disclosure reflecting the content requirements under section 113 that plan administrators may use to discharge their stat…
  4. Notice 2010-6 — This notice provides rules governing the taxation of nonqualified deferred compensation plans. Section 409A of the Code requires that a nonqualified deferred c…
    IRCNoticesModified Jan 19, 2010
    100x as an operational failure under Notice 2008-113 and Employee H repays Employer the $100x and meets all the other requirements of Notice 2008-113. Conclusion: Because the plan provision defining disability was corrected and all payments received under the plan due to the impermissible payment event were treated as …
  5. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …determination as to the abatement of interest. See sec. 6404(h); Rule 280(b); Gati v. Commissioner, 113 T.C. 132, 134 (1999); Bourekis v. Commissioner, 110 T.C. at 25-26. - 78 - [*78] APPENDIX SUMMARY OF RESPONDENT'S BANK DEPOSITS ANALYSES 1992 Ms. Zaklama BOA3886 FFB2740 Total Deposits $66,985 $483,616 $550,601 Less: …
  6. Ann. 2015-13 — This announcement explains the effect of H.R. 2591, which became Public Law 113–243. The announcement also explains how taxpayers should report the rollover of…
    IRCAnnouncementsApr 13, 2015
    Announcement 2015–13 Reporting Airline Payment Amount Rollovers Under Public Law 113–243 PURPOSE This announcement explains how taxpayers must report rollovers of airline payment amounts under recently enacted Public Law 113–243 (“P.L. 113–243”), which amended certain provisions of the FAA Modernization and Reform Act …
  7. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …ction and copying. Comments may be submitted to Internal Revenue Service, CC:PA:LPD:RU (Notice 2008-113), Room 5203, PO Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may also be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to the Courier’s Desk at 1111 Constitution Ave…
  8. Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022
    IRCNoticesModified Jan 8, 2024
    …ieu of receiving cash will not violate the contingent benefit rule of section 401(k)(4)(A). Section 113(b) of the SECURE 2.0 Act amended section 403(b)(12)(A) of the Code to provide that a plan does not fail to satisfy section 403(b)(12)(A)(ii) solely by reason of offering a de minimis financial incentive (not derived …
  9. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  10. IRCRegulationsJul 26, 2016
    …2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Survivor Annuities; Two Lives—Expected Return Mult…
  11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    d comments from various interested persons, and held a public hearing. Where Treasury erred, Judge Toro’s dissent argues, was in failing to adequately respond to the four comments relating to the blocked income regulation. And because of that failure, according to Judge Toro’s dissent, the regulation should be invalida…
  12. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  13. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    prohibited transaction. We do not decide the issue, however, because there remain genuine issues of material fact precluding partial summary judgment. Under Rule 121(b), summary judgment is appropriate “if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together w…
  14. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  15. 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…
  16. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999related by meaning
    r's Life. Respondent further determined that petitioner is liable for the addition to tax under section 6651(a) for his failure to file a 1992 Federal income tax return. - 5 - OPINION Petitioner does not deny receipt of any of the items of income. Nor does he claim that any particular item of income has been overstated…
  17. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  18. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975); …
  19. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
  20. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.