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90 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    until the restriction was lifted. Id. The Tax Court held that because section 482 of the Internal Revenue Code of 1954 does not apply, the regulations under section 482 of the Internal Revenue Code of 1954 do not apply. Procter & Gamble Co. v. Commissioner , 95 T.C. at 340-341. Excerpted in full below is the Tax Court’…
  2. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006related by meaning
    rough prosecution of a legal suit or action based upon tort or tort type rights, or - 14 - through a settlement agreement entered into in lieu of such prosecution.” Sec. 1.104-1(c), Income Tax Regs. Thus, the exclusion must derive from some sort of tort claim against the payor. Rickel v. Commissioner , 900 F.2d 655, 65…
  3. Treas. Reg. § 54.9815-1251(g)(5) — Preservation of right to maintain existing coverage.
    IRCRegulationsJan 14, 2021
    …al inflation (as defined in paragraph (g)(4)(i) of this section) from March 2010 is 0.2269 (475−387.142 = 87.858; 87.858 ÷ 387.142 = 0.2269). The maximum percentage increase permitted is 37.69% (0.2269 = 22.69%; 22.69% + 15% = 37.69%). Because 33.33% does not exceed 37.69%, the change in the copayment requirement at th…
  4. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the legislative intent, the rule of section 457(e)(1) does not apply and Foil’s 1981 employee contributions are not taxed until made available to him. Respondent maintains that section 252 of TEFRA removes “qualified State judicial plans” from the application of section 131 of R.A. 1978 but it does not provide any spec…
  5. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020★ strong match
    little more than guesswork and failed to satisfy the strict substantiation requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section 274(d). Cons…
  6. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005
    …s. On their joint Federal income tax return for 2000, petitioners reported as gross income the $115,142.97 in distributions from their qualified plans. Petitioners included with their 2000 tax return Form 5329, Additional Taxes Attributable to IRAs, Other Qualified Retirement Plans, Annuities, Modified Endowment Contra…
  7. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015
    …3001(c), 112 Stat. at 727, and the taxpayer in that case anyway bore the burden of proof under Rule 142(a), see Matthews v. Commissioner, 92 T.C. at 361-362 (citing Rule 142(a), and Welch v. Helvering, 290 U.S. 111, 115 (1933)). Moreover, none of the recent cases that relied on Bunney cited or discussed the applicabili…
  8. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    Commissioner, 142 S. Ct. at 1501. In doing so, the Sup reme Court rejected the Commissioner’s argument that the express jurisdictional text of section 6330(e)(1) suggested that the deadline under section 6330(d)(1) was also jurisdictional. Boechler, P.C. v. Commissioner, 142 S. Ct. at 1499– 500. The Supreme Court state…
  9. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  10. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
  11. 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…
  12. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  13. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
  14. T.C. Summary Opinion 2014-50 — Joel G. Nganga v. Commissioner
    IRCCourt RulingsJun 4, 2014
    rect, and the taxpayer bears the burden of showing that those determinations are erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). 5 At no time since calendar call has the Court heard from petitioner. _ 9 _ Pursuant to section 7491(a)(1), the burden of proof as to factual matters may shift from the …
  15. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025
    …that a PCT Payment falling within Dr. Newlon’s range is reasonable and chose the midpoint . 51 Rule 142(a) , shifting the burden of proof to respondent. We then discuss the extent to which we will consider posttransaction evidence. Finally, we address the scope and standard of review under section 482. I. Burden of pro…
  16. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …hours. Applying a labor rate for an Independent Producer results in: (4,278 hours × $165.29) ≉ $707,142. For insurers: 358 insurers × 73.1% proportion of entities that are small × 1 hour ≉ 261 hours. Applying a labor rate for a legal professional results in: (261 hours × $165.71) ≉ $43,303. Combining the costs for both…
  17. 86 FR 51488 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Sep 15, 2021
    … the IRS and the DOL.   DOL IRS Hours Costs Hours Costs Pension: Large Plans 261,464 $62,431,639.11 142,897 $31,568,313.36 Small Plans 174,999 87,694,622.39 176,481 103,113,327.32 Welfare: Large Plans 108,142 111,593,190.83 9,953 1,811,627.38 Small Plans 6,137 5,407,649.86 2,507 1,252,295.71 Total: Large Plans 369,607 …
  18. Rev. Rul. 2021-3 — Section 401. —Qualified Pension, Profit-Sharing, and Stock Bonus Plans
    IRCRevenue RulingsFeb 1, 2021
    …1981 2048 139,380 1982 2049 140,124 1983 2050 140,820 1984 2051 141,504 1985 2052 141,960 1986 2053 142,368 1987 2054 142,644 1988 and Later 2055 and Later 142,800 ATTACHMENT II 2021 ROUNDED COVERED COMPENSATION TABLE CALENDAR YEAR OF BIRTH 2021 COVERED COMPENSATION ROUNDED 1937 $ 39,000 1938 – 1939 45,000 1940 48,000 …
  19. 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)…
  20. Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o…
    IRCRevenue RulingsSep 8, 2014
    …14–50 Rev. Proc. 2014–50 This revenue procedure automatically suspends certain requirements under § 142(d) for qualified residential rental projects financed with exempt facility bonds issued by state and local governments under § 142. The revenue procedure suspends these requirements for one year following a President…