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Go to 16 T.C. 256 (not yet in the library — opens the official source)
75 documents · 0.60sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    nsolidated group as “consistent with the 1986 statutory amendment” and “supported by the language of the 1986 amendment.” Such allocation is in fact 1 We also note that, if we were to agree with 3M in the present case, we would be giving primary weight to a Brazilian legal restriction that was not publicly promulgated,…
  2. T.C. Memo. 2013-126 — Laura Ung v. Commissioner
    IRCCourt RulingsMay 13, 2013
    …cedes that she received a taxable distribution from her Fidelity Investments retirement account of $256 that was unreported for 2008. Finally, petitioner concedes that she received a $20,000 taxable distribution from her Morgan Stanley retirement account that was originally unreported on her 2008 tax return. - 3 - [*3]…
  3. T.C. Memo. 2006-95 — Theodus J. Jordan v. Commissioner
    IRCCourt RulingsMay 8, 2006
    …1,725 of the $1,738 offset amount, along with $531 of Federal income tax withheld, in claiming a $2,256 overpayment. In the notice of deficiency, respondent increased petitioner’s deficiency by $2,256, with an explanation that this adjustment reflected the disallowance of an additional child tax credit. The parties hav…
  4. REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv…
    IRCProposed Rules (FR)Proposed May 28, 2013
    …x 5%)) on December 31, 2017; $33,101 ($21,525 + $10,000 + ($31,525 x 5%)) on December 31, 2018; $45,256 ($33,101 + $10,000 + ($43,101 x 5%)) on December 31, 2019; and $58,019 ($45,256 + $10,000 + ($55,256 x 5%)) on December 31, 2020.
  5. PLR 200939018 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)
    IRCPrivate Letter RulingsSep 25, 2009
    …s basic function the systematic liquidation of the principal.” Se e also Comm’r v. Meyer , 139 F.2d 256 (6th Cir. 1943). Similarly, in Rev. Rul. 75-255, 1975-2 C.B. 22, the Service observed
  6. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …nefits and DWB's as shown below: 1989 1990 1991 1992 1993 1994 Total DWB's (number) 0 6 50 57 87 56 256 Withdrawal dist. $468,274 $2,292,366 $3,848,663 $10,732,521 $6,227,028 $4,117,684 $27,686,536 DWB's (amount) 0 11,985 682,394 640,125 727,947 671,783 2,734,234 Total 468,274 2,304,351 4,531,057 11,372,646 6,954,975 4…
  7. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    oner , supra at 780. 11 See id. at 773. 12 See Eckel v. Commissioner , T.C. Memo. 1990-174. 13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 sect…
  8. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …ted parties. If both applications result in a published proposed exemption each year, approximately 256 notices to interested parties will be distributed to the QPAMs' client Plans, and, if the proposed exemption is granted, an objective description also must be distributed to interested parties that describes the fact…
  9. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …rt higher premiums (29 percent compared to 41 percent) than those utilizing the three largest PBMs.[256]
  10. T.C. Memo. 2015-164 — Edward N. Tobias & Suzanne M. Koegler v. Commissioner
    IRCCourt RulingsAug 18, 2015
    …010, the day petitioners made their withdrawal, the cash value of the ING annuity contract was $761,256. Petitioners thus had $186,302 of "income on the contract" (cash value of $761,256 minus their "investment in the contract" of $574,954). Because the amount of the withdrawal, or $525,000, ex5When Allstate passed the…
  11. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    entity that no longer exists. E at 522.¹5 This resulted in a "double benefit" that the Commissioner said Congress didn't intend and that a regulation forbade. R at 528. But the Court upheld the structure because it "fit[] solidly within the literal language of the statute." R at 527. It also noted that the taxpayer wa…
  12. 80 FR 2010 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Jan 15, 2015
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 256 is added to 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 annuities (perc…
  13. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  14. Treas. Reg. § 54.4975-7(b)(8)(iv) — Other statutory exemptions.
    IRCRegulationsDec 30, 2016
    …antees the loan, which is for 15 years at 5% interest and is payable in level annual amounts of $72,256.72. Total payments on the loan are $1,083,850.80. The ESOP uses the entire loan proceeds to acquire 15,000 shares of X stock which is used as collateral for the loan. The number of securities to be released for the f…
  15. T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules.
    IRCTreasury DecisionsSep 18, 2006related by meaning
    nder section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. ADMINISTRATIVE Rev. Proc. 2006-34 Rev. Proc. 2006-34 This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, electronically or magnetically. The procedure …
  16. 29 C.F.R. § 2550.408b-3(h)(4) — Loans to Employee Stock Ownership Plans.
    ERISARegulationsJan 1, 2017
    …rantees the loan which is for 15 years at 5% interest and is payable in level annual amounts of $72,256.72. Total payments on the loan are $1,083,850.80. The ESOP uses the entire proceeds of the loan to acquire 15,000 shares of X stock which is used as collateral for the loan. The number of securities to be released fo…
  17. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
  18. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  19. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  20. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …