Brief Case
Pension Resource

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 122 T.C. 73 (not yet in the library — opens the official source)
94 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    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 …
  2. Treas. Reg. § 54.9802-3T(e) — Additional requirements prohibiting discrimination based on genetic information (temporary).
    IRCRegulationsDec 30, 2016
    …test before the claim is paid. (ii) Conclusion. See Example 1 in 29 CFR 2590.702-1(e) or 45 CFR 146.122(e) for a conclusion under the rules of paragraph (c)(4) of 29 CFR 2590.702-1 or 45 CFR 146.122 similar to the rules of paragraph (c)(4) of this section that the issuer is permitted to request only the minimum amount …
  3. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    taxpayer in a CDP hearing can challenge the liability for interest. Urbano v. Commissioner, 122 T.C. 384, 390 (2004); Montgomery v. Commissioner, 122 T.C. 1, 8 (2004). A challenge to liability for interest can be premised on the interest-abatement provisions of section 6404(e)(1). See Urbano v. Commissioner, 122 T.C. …
  4. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    r in the computation of the sec. 72(t) tax, her petition raised the issue whether she should have been subject to any additional tax under sec. 72(t). Sec. 402(e)(1) has been redesignated sec. 402(d) by the Unemployment Compensation Amendments of 1992, Pub. L. 102-318, sec. 521(a) and (b), 106 Stat. 290, 300-310, 313, …
  5. 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…
  6. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    ate is applied in the following calculation: 26,659 claims × 1 hour × $122.55 = $3,267,013. Total burden hours are 26,659 hours. Back to Citation 301.  The burden is estimated as follows: 26,659 claims × 2 hours = 53,317 hours. A labor rate of $122.55 is used for a general and operations manager. The labor rate is appl…
  7. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …pondent determined in Ms. Zaklama's notice of deficiency that she realized unreported income of $11,122, $22,520, $8,502, $50,003, $11,662, and $2,840 during the subject years, respectively. Respondent determined in Mr. Zaklama's notice of deficiency that he realized unreported income of $120,695, $110,020, and $88,250…
  8. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
  9. T.C. Memo. 2014-27 — Boyd J. Black & Janice C. Black v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …elvering, 290 U.S. 111, 115 (1933); ci secs. 6201(d), 7491(a).3 The submission of a case under Rule 122 does not alter the taxpayer's burden of proof. Rule 122(b); see Borchers v. Commissioner, 95 T.C. 82, 91 (1990), aff'd, 943 F.2d 22 (8th Cir. 1991). As presented by the parties and on the basis of the stipulated fact…
  10. 89 FR 5624 — Automatic Portability Transaction Regulations
    ERISAProposed Rules (FR)Proposed Jan 29, 2024
    … Distribution Limit) Coverage/Match Factor 65% 65% 65% 65% 65% 65% 65% 65% 65% 65% Default IRAs 810,122 810,122 810,122 810,122 810,122 810,122 810,122 810,122 810,122 810,122 8,101,220 Accounts with AP 526,579 526,579 526,579 526,579 526,579 526,579 526,579 526,579 526,579 526,579 5,265,790 AP Transfers 337,484 337,48…
  11. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  12. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  13. 78 FR 17313 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Mar 21, 2013
    …with respect to genetic nondiscrimination (found in § 146.121(b), § 146.121(c), § 146.121(e), § 146.122(b), § 146.122(c), § 146.122(d), and § 146.122(e)) do not apply to any group health plan (and group health insurance coverage) for any plan year, if on the first day of the plan year, the plan has fewer than two parti…
  14. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    …fore Jan. 1, 1988, and is thus inapplicable here. Sec. 402(a)(2) was subsequently repealed by sec. 1122(b)(1)(A) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2466. SEC. 402(e). Tax on Lump Sum Distributions.—
  15. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …le 4/40 4/40 4/40 4/40 Normal retirement age Same as 401(a) Same Same Same Death benefit multiple 4.122 2.692 4.122 4.122 Date executed 07/31/90 07/31/90 07/30/91 10/01/91 D. Administration of N.L. Booth's Account in the Prime Plan On August 12, 1991, IFTI forwarded the 1990 annual report for N.L. Booth's account in th…
  16. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    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…
  17. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    one taxable year; at best, petitioner's assertion undermines the characterization of the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case. c. Frozen Deposit Rule Finally, although it is not clear whether petitioner relies on the special rule for frozen deposits f…
  18. 78 FR 77632 — Amendments to Excepted Benefits
    IRCProposed Rules (FR)Proposed Dec 24, 2013
    …  Public Law 104-204, 110 Stat. 2944 (September 26, 1996). Back to Citation 2.  Public Law 110-343, 122 Stat. 3881 (October 3, 2008). Back to Citation 3.  Public Law 104-204, 110 Stat. 2935 (September 26, 1996). Back to Citation 4.  Public Law 105-277, 112 Stat. 2681-436 (October 21, 1998). Back to Citation 5.  Public …
  19. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  20. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …our for IRAs)] × $165.71 per hour ≉ $1,007,508. Back to Citation 73.  The burden is estimated as: [(122,318 IRAs + 10 investment company principal underwriters for IRAs × 28.2 percent paper) × (2 minutes ÷ 60 minutes)] ≉ 1,150 hours. A labor rate of $65.99 is used for a clerical worker. The labor rate is applied in the…