IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
Notice 2021-57 — Notice 2021-57 provides guidance to multiemployer defined benefit pension plan sponsors and actuaries on the application of funding relief under IRC § 431 and … IRCNoticesNov 1, 2021
… plan sponsor’s calculations of plan losses unless such calculations are clearly erroneous. Section 431(b)(8)(B)(iii) provides that if both the special amortization rule of section 431(b)(8)(A) and the special asset valuation rule of section 431(b)(8)(B) apply for a plan year, then the plan is required to treat any red…
83 FR 57592 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…0(a)(1) and (a)(1)(iv)).
2. Exemption for Objecting Entities Based on Moral Convictions (45 CFR 147.133(a))
3. Exemption for Certain Plan Sponsors (45 CFR 147.133(a)(1)(i))
a. Plan sponsors in general (45 CFR 147.133(a)(1)(i) prefatory text)
b. Nonprofit organizations (45 CFR 147.133(a)(1)(i)(A))
c. For-Profit Entities…
Notice 2010-83 — Funding relief for multiemployer defined benefit plans under PRA 2010. This notice provides guidance in the form of questions and answers for sponsors of multi… IRCNoticesDec 20, 2010
…rules substantially similar to the rules prescribed by the Secretary for purposes of § 165.
Section 431(d) provides for the extension of certain amortization periods applicable under § 431. Under § 431(b)(8)(A)(ii)(I), the amortization period under the special amortization rule cannot be further extended under § 431(d)…
Rev. Proc. 2010-52 — This document describes the procedure by which the plan sponsor of a multiemployer pension plan may request and obtain approval of an extension of an amortizat… IRCRevenue ProceduresDec 27, 2010
…cretary of the Treasury has interpretive and enforcement jurisdiction over both provisions. Section 431(d)(1) provides that if the plan sponsor of a multiemployer plan submits to the Secretary of the Treasury an application for an extension of the amortization period for any unfunded liability described in § 431(b)(2)(…
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…he reference “147.131 and 147.132” and adding in its place the reference “147.131, 147.132, and 147.133”.
§ 54.9815-2713AT
[Amended]
3. Section 54.9815-2713AT, as added elsewhere in this issue of the Federal Register
], is amended—
a. In paragraph (a)(1) by removing “or (ii)” and adding in its place “or (ii), or 45 CFR…
Notice 2010-56 — This notice provides guidance on filing Form 5500 and Schedule MB for multiemployer defined benefit plans for plan sponsors who are considering use of the spec… IRCNoticesAug 16, 2010
…rtifications already made. In the case of an applicable plan year that ends before guidance under § 431(b)(8) is issued, the special rules may be applied for the applicable plan year (subject to the requirements of § 431(b)(8), including the restriction on plan amendments under § 431(b)(8)(D)) without regard to whether…
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…
IRCCourt RulingsFeb 9, 2023related by meaning
d. Reg. 17775), dated May 13,
1993 (58 Fed. Reg. 28446), dated May 18, 1993 (58 Fed.
Reg. 28921).” In our view, while the first correction related
214 to both the 1993 temporary regulation and the 1993 notice
of proposed rulemaking, the second and third corrections
related only to the 1993 temporary regulations. They d…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
…ing 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (1957), relied upon by petitioner, are clearly distinguishable on their facts.
82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking IRCProposed Rules (FR)Proposed Oct 13, 2017
…a. In paragraph (a)(1) by removing the language “(ii)” and adding in its place “(ii), or 45 CFR 147.133(a)(1)(i) or (ii)”. b. In paragraph (a)(2) by adding the language “or 147.133(a)” after “147.132(a)”.
c. In paragraph (b)(1)(ii) introductory text by removing the language “147.132” and adding in its place “147.132(ii…
Rev. Proc. 2008-67 — This document sets forth the procedure by which the sponsor of a multiemployer pension plan may request and obtain approval of an extension of an amortization … IRCRevenue ProceduresSuperseded Dec 1, 2008
…cretary of the Treasury has interpretive and enforcement jurisdiction over both provisions. Section 431(d)(1) provides that if the plan sponsor of a multiemployer plan submits to the Secretary of the Treasury an application for an extension of the amortization period for any unfunded liability, and includes the certifi…
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 RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
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.
IRCCourt RulingsMay 30, 1984related by meaning
was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
REG-143601-06 — Proposed regulations under section 430 of the Code provide generally applicable mortality tables to be used in determining present value or making any computat… IRCProposed Rules (FR)Proposed Jun 11, 2007
… to individuals who are disabled within the meaning of Title II of the Social Security Act. Section 431, which was added by PPA, specifies the minimum funding requirements that apply to multiemployer plans. Under section 431(c)(6)(B), a plan’s full funding limitation cannot be less than the excess (if any) of 90 percen…
IRCPrivate Letter RulingsJan 21, 2011
'"- \
Significant Index Number 0431.00-00
201103059
DEPARTMENTOFTHETREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
• TAX EXEMPT AND
OCT 27 lOlO
GOVERNMENT ENTITIES
DIVISION
Re:
Taxpayer
=
Dear
This letter constitutes notice that approval has been granted for your request
for
a 5-year automatic extension for am…