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82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …39, ch. 2, sec. 45, 53 Stat. at 25. Sec. 29.45-1, Regulations 111, 26 C.F.R. sec. 29.45-1, at 6141-6142 (Cum Supp. 1944). 1943 Internal Revenue Code of 1939, ch. 2, sec. 45, 53 Stat. at 25. Sec. 29.45-1, Regulations 111, 26 C.F.R. sec. 29.45-1, at 6141-6142 (Cum Supp. 1944). 1945 Internal Revenue Code of 1939, ch. 2, s…
  2. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    or knowing Recordkeeping $20-198 $198-396 $396-989 Monetary violations 20-198 198-396 Employment of homeworkers without a certificate 198-396 396-989 Other violations of statutes, regulations or employer assurances 20-198 198-396 396-989 PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 23. The…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  4. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …erceived problems with the discretionary award regime. See Whistleblower 11332-13W v. Commissioner, 142 T.C. 396, 400 (2014). TRHCA sec. 406 amended section 7623 to require the Secretary to pay whistleblower awards under certain circumstances. TRHCA sec. 406(a)(1)(D), 120 Stat. at 2959 (adding to section 7623(b)). Unde…
  5. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
    IRCRegulationsSep 9, 2016
    …iated with Participant E's assumed age 50 withdrawal benefit in the 2009 actuarial valuation is $68,396.75. This is equal to the sum of: $6,925.29, which is the present value of payments expected to be made during the year the participant turns age 65 (the 20th year after the valuation date), using the second segment i…
  6. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    … the payment should be applied, the Service must follow such designation. Hirsch v. United States , 396 F. Supp. 170, 172 (S.D.Ohio1975), 75-1 USTC ¶9348, 35 A.F.T.R.2d 75-1358. See also , Muntwyler v. United States , 703 F.2d 1030, 1032 (7 th Cir.1983) (citing O’Dell v. United States , 326 F.2d 451, 456 (10 th Cir.196…
  7. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976related by meaning
    ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue. (b) Retroactivity of R…
  8. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
  9. 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…
  10. 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…
  11. 77 FR 74063 — Amendments to the Abandoned Plan Regulations
    ERISAProposed Rules (FR)Proposed Dec 12, 2012
    … sent by mail and that the rest will be submitted electronically (495 plans × .8 fraction by mail = 396 plans send notice by mail). Therefore, mailing costs include $6.35 for postage and email receipt of delivery. The mailing costs include paper and print cost of five cents per page. The model notice is three pages. Th…
  12. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …,396.38 296,422.12 226,410.78 344,676.76 Net Income 137,240.45 119,003.00 177,976.62 182,794.88 120,142.22 50,694.24 In addition, Liberty Commerce Group Trust received dividends from Capitol Federal Financial of $30 in 1999, $46 in 2000, $62 in 2001, $ 200 in 2002, $ 200 in 2003, and $200 in 2004, and interest payments…
  13. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  14. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …r section 72(t). 3 - 3 - Commissioner , 89 T.C. 46, 48 (1987); Atlee v. Commissioner , 67 T.C. 395, 396 n.2 (1976); Hedrick v. Commissioner , 63 T.C. 395, 396-397 (1974); Alexander v. Commissioner , 61 T.C. 278, 288 n.6 (1973); Stengel v. Commissioner , T.C. Memo. 1992-570, affd. without published opinion 996 F.2d 1227…
  15. 50 T.C. 583 — Audrey Realty, Inc. v. Commissioner
    IRCCourt RulingsJul 18, 1968related by meaning
    62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963). In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
  16. 85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 7, 2020
    …100 3,100 2026 751 751 3,172 3,172 2027 768 768 3,245 3,245 2028 786 786 3,319 3,319 2029 804 804 3,396 3,396 2030 822 822 3,474 3,474 2031 or later 841 841 3,554 3,554 1  Applicable tables for valuation dates before 2021 are available on PBGC's website ( www.pbgc.gov). 2  Table II-A. 3  Table II-B. 4  Table II-C. * * …
  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. 83 FR 63802 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 12, 2018
    … 2026 751 751 3,172 3,172 2027 768 768 3,245 3,245 2028 786 786 3,319 3,319 2029 or later 804 804 3,396 3,396 1  Applicable tables for valuation dates before 2019 are available on PBGC's website ( www.pbgc.gov). 2  Table II-A. 3  Table II-B. 4  Table II-C. ( printed page 63804) * * * * * Issued in Washington, DC. Hilar…
  19. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent. Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
  20. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    …of the measurement date in each such taxable year). The present value of that future payment is $35,396 as of December 31, 2015; $37,166 as of December 31, 2016; and $39,024 as of December 31, 2017. Therefore, for purposes of attributing the $60,000 payment on January 1, 2020, the present value of future payments as of…