Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 121 T.C. 273 (not yet in the library — opens the official source)
97 documents · 0.54sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 54.9802-1(c)(2)(iii) — Prohibiting discrimination against participants and beneficiaries based on a health factor.
    IRCRegulationsDec 30, 2016
    …se of F's claims experience. (ii) Conclusion. See Example 1 in 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) for a conclusion that the issuer does not violate the provisions of 29 CFR 2590.702(c)(2) and 45 CFR 146.121(c)(2) similar to the provisions of this paragraph (c)(2) because the issuer blends the rate so that t…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    s at issue in First Security Bank . Such a determination would not inform our understanding of the holding or reasoning of First Security Bank . GG. T he Tax Reform Act of 1976 In 1976, Congress amended section 482 of the Internal Revenue Code of 1954 to replace “the Secretary or his delegate” with “the Secretary”. 26 …
  3. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011★ strong match
    … there is no genuine issue of materïal fact and a decision may be rendered as a matter of law. Rule 121(a) and (b); Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). The moving party bears the burden of proving that there is.no genuine issue of material fact, and factual inferences are.viewed in a light most f…
  4. 78 FR 33158 — Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
    IRCFinal Rules (FR)Jun 3, 2013
    ….C. 300gg-1 through 300gg-5, 300gg-11 through 300gg-23, 300gg-91, and 300gg-92) (1996). Section 146.121 is also issued under secs. 2701 through 2763, 2791, and 2792 of the Public Health Service Act (42 U.S.C. 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended (2010). 8. In § 146.121, paragraph (f) is revised t…
  5. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …. Accordingly, the increase in Plan P's prefunding balance as of January 1, 2011, cannot exceed $43,273 (which is the present value of the excess contribution of $40,824 adjusted for 12 months of interest at an effective interest rate of 6%).(iii) Plan P's funding standard carryover balance as of January 1, 2011, is $2…
  6. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  7. 81 FR 38948 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits
    PBGCFinal Rules (FR)Jun 15, 2016
    …) On or after Before i1 i2 i3 n1 n2   *         *         *         *         *         *         * 273 7-1-16 8-1-16 0.75 4.00 4.00 4.00 7 8 3. In appendix C to part 4022, Rate Set 273, as set forth below, is added to the table. Appendix C to Part 4022—Lump Sum Interest Rates for Private-Sector Payments * * * * * Rate…
  8. 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…
  9. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …(B) (A × B) (C) (A × B × C) (D) (A × D) Service providers prepare information (non-bulk) 326 2 652 $121.53 $79,238 $10.10 $3,293 Service providers prepare information (bulk) 2 20 40 121.53 4,861 10.10 20 Service providers maintain recordkeeping for SCC 909 0.17 152 121.53 18,412 Total 1,237 844 102,511 3,313 VFCP Class…
  10. 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…
  11. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    …ion for summary judgment anc respondent's cross-motion for - 3 - summary judgment spursuant to Rule 121. Respondent determined a deficiency of $33,057 in petitioner's Federal rincome tax for tax
  12. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …Total Responses: 198. Frequency of Response: Annual. Estimated Total Burden Hours: 935,600 (DOL—425,273, Treasury—425,273, OPM—85,055). Estimated Total Cost Burden:
  13. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007
    …ted its then-current cash value. The loan balance on the house included the balance on a mortgage ($121,155), and the balance on a home equity line of credit ($43,000). Petitioners reported gross monthly income of $5,252, representing Mr. Andrews’s wage income of $2,382, and Mrs. Andrews’s pension/Social Security incom…
  14. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  15. Treas. Reg. § 1.401(a)(9)-6(m)(4)(ii)(A) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    …alue of the death benefit in excess of the notional account balance in 2028 is determined to be $97,273 (24 percent of the notional account balance). The following two tables summarize the actuarial methodology used in determining the actuarial present value of the additional benefit. Table 4 to Paragraph (m)(4)(ii)(A)…
  16. 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…
  17. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …d Total Responses: 198 Frequency of Response: Annual Estimated Total Burden Hours: 935,600 (DOL–425,273, Treasury–425,273, OPM–85,055)
  18. Treas. Reg. § 1.412(c)(2)-1(b)(9) — Valuation of plan assets; reasonable actuarial valuation methods.
    IRCRegulationsSep 9, 2016
    …0 $238,000 $228,000 Net adjustments: 1988 40,500 40,500 40,500 1987 38,500 38,500 1986 44,500 Total 273,500 275,500 278,500 228,000 Average value: 1988 = $273,500 + $275,500 + $278,500 + $228,000 ÷ 4 = $263,875 (ii) Plan F properly determines an average value under paragraph (b)(7) of this section for use as an actuari…
  19. T.C. Memo. 2012-37 — Ifeanyi David & Ann Ada Onyekwena v. Commissioner
    IRCCourt RulingsApr 26, 2012related by meaning
    ed in section 274(d). Sanford v. Commissioner, 50 T.C. 823, 827 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969); Rodriguez v. Commissioner, T.C. Memo. 2009-22 (the strict substantiation requirements of section 274(d) preclude the Court and taxpayers from approximating certain expenses). r - 12 - Petitioners' tabl…
  20. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    s not being an employee, and only if the taxpayer has not, after 1977, treated any individual holding a substantially similar position as an employee. "The Clinic has continuously treated its shareholder doctors as employees. Therefore, under section 530(a)(3) of the Act, the Clinic would not be entitled to section 530…