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 138 T.C. 295 (not yet in the library — opens the official source)
86 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 86 FR 57272 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
    ERISAProposed Rules (FR)Proposed Oct 14, 2021
    …that there are 67,862 plans that will need to ensure compliance with the proposal. A labor rate of $138.41 is used for a lawyer. The cost burden is estimated as follows: 4 hours * $138.41 = $553.64. Labor rates are based on DOL estimates from Labor Cost Inputs Used in the Employee Benefits Security Administration, Offi…
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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 …
  4. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …he agreement recited that MIT 80 agreed to accept the 500 shares from MPC in full payment of the $1,295,108 due to it from MPC. None of the parties to this transaction were represented by counsel. No one made a formal appraisal of the MIT Transportation Co. stock. Bruce nevertheless issued a memorandum to the MIT 80 pa…
  5. 75 FR 43330 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient…
    IRCFinal Rules (FR)Jul 23, 2010
    arket Total Enrollees (millions) 138.0 39.0 15.1 138.0 39.0 15.1 138.0 39.0 15.1 Non-Grandfathered Enrollees 24.4 6.9 6.0 44.5 12.6 9.7 61.0 17.2 11.8 Total Claims (millions) 248.9 70.4 61.5 453.8 128.3 98.5 622.4 175.9 120.6 Pre-Service: Claim Approved 6.3 1.8 1.6 11.6 3.3 2.5 15.9 4.5 3.1 Claim Denied 1.1 0.3 0.3 2.0…
  6. 85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA
    ERISAFinal Rules (FR)May 27, 2020
    …e approximately 296,000 hours to develop and review the initial notice. Assuming an hourly rate of $138.41 for in-house attorneys, the Department estimates developing the initial notice will cost approximately $41 million (295,636 hours * $138.41). Then $41 million is discounted at three percent, which leads to $40 mil…
  7. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    …Fed. Cir., Nov. 1, 1990). The Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388, while maintaining this option for a severely limited class of eligible individuals, suspended it for 5 years for the vast majority of CSRS employees. The portion of sec. 72(e) involved herein reads as follows:
  8. 83 FR 15019 — Real Estate Appraisals
    IRCFinal Rules (FR)Apr 9, 2018
    ….8 billion by 6.05 percent then dividing the product by an average loan amount of $375,000 equals 5,138 loans. Back to Citation 73.  The FDIC estimates that the average hourly compensation for a loan officer is $67.29 an hour. The hourly compensation estimate is based on published compensation rates for Credit Counselo…
  9. 83 FR 15946 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Apr 13, 2018
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 295 is added at the end of the table to read as follows: Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annu…
  10. 75 FR 65263 — Definition of the Term “Fiduciary”
    ERISAProposed Rules (FR)Proposed Oct 22, 2010
    …lars) Year Cost of legal review undiscounted (A) Total 3% discounting Total 7% discounting 2011 $10,138,000 $10,138,000 $10,138,000 2012 845,000 820,000 790,000 2013 845,000 796,000 738,000 2014 845,000
  11. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein, Decision will be entered for the respondent. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
  12. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    rs, as it was required to do. See Frederick Vietor & Achelis v. Salt’s Textile Mfg. Co., 26 F.2d 249, 255 (D. Conn. 1928); O.D. 419, 2 C.B. 60 (1920). What is more, petitioner claimed its foreign tax credit in dollars. It would thus appear that petitioner’s position should be rejected, since section 905(c) speaks in te…
  13. 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…
  14. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  15. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998★ strong match
    T.C. Memo. 1998-295 UNITED STATES TAX COURT SHEDCO, INC., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17268-95R. Filed August 12. 1998. John F. Daniels III and Neil H. Hiller , for petitioner. Ann W. Durning and J. Robert Cuatto , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARR, …
  16. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013
    … from the IRA to CST.7 On or about August 19, 2005, Mr. Ellis received a second distribution of $67,138.81 from the section 401(k) account he had accumulated at Aventis Pharmaceuticals.8 9 As with the first distribution check, Mr. Ellis deposited the entire $67,138.81 into his IRA. On or about August 23, 2005, Mr. Elli…
  17. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  18. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …9.00 -0- 239.00 Legal & prof. 1,785.04 615.16 -0- 615.16 Mortg. interest 3,558.53 3,558.53 3,420.45 138.08 Repairs -0- 138.40 -0- 138.40 Taxes 424.00 424.00 509.04 (85.04) Utilities 107.97 310.05 107.97 202.08 Termite control 265.00 -0- -0- -0Home shield 450.00 -0- -0- -0Prop. mgt. 400.00 -0- -0- -0Federal Express 14.0…
  19. PBGC Op. Ltr. 1993-2 — Withdrawal liability
    PBGCPBGC Opinion LettersJul 7, 1993
    …ately [*3] preceding the 3-year testi ng perio d. ER ISA § 42 06( a)(2 )(A) a nd (B ); 29 U .S.C. § 138 6(a) (2)(A ) and (B) . You ask whether the numerator of the fract ion is t he contribution base unit s for the plan y ear following the hypothet ical complete withdrawal (i. e., the second plan ye ar in the 3 -year t…
  20. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…