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85 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    regulation s in 1944. T.D. 5426, 10 Fed. Reg. 23, 24 (Jan. 2, 1945); 26 C.F.R. sec. 29.45-1, at 1905 (1944 Supp.); 26 C.F.R. sec. 29.45-1 (194 9). • T he relevant portion of the 1953 regulations was sec. 39.45-1(b)(1), Regulations 118, Income Tax Regulations 118, Internal Revenue Code Part 39 of Title 26, Code of Feder…
  2. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
  3. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …ncome 232,158 382,445 351,722 106,927 96,476 Taxes 10,306-0-13,572-0-7,519 Fiduciary fees 53,836 63,293 22,994-0 - - 0 - Attorney, accountant 13,247 136,440 96,205 104,764 173,804 Other deductions 3,500-0-16 1,761 10,547 Other deductions: mgmt/admin fees-0 - - 0-173,550 79,263 128,000 Exemption 100 100 100 100 100 Taxa…
  4. Treas. Reg. § 1.417(a)(3)-1(e) — Required explanation of qualified joint and survivor annuity and qualified preretirement survivor annuity.
    IRCRegulationsSep 9, 2016
    …rial present value of $498,089, while the single-sum payment has an actuarial present value of $224,293 (i.e. the amount of the single sum is $224,293) and that the single life annuity is approximately equal in value to the QJSA. The explanation states that the relative value comparison converts the value of single lif…
  5. 83 FR 6956 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Feb 16, 2018
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 293 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…
  6. 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…
  7. 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…
  8. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997★ strong match
    …ons To Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) - 2 - 1992 $13,005 $3,251 $457 1993 5,172 1,293 217 Susan W. Cujas Additions To Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1992 $4,528 $1,132 $127 1993 5,172 1,293 217 All section references are to the Internal Revenue Code in effect for the years in issue, …
  9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    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 …
  10. 88 FR 11793 — Annual Reporting and Disclosure
    ERISAFinal Rules (FR)Feb 24, 2023
    …-plans. Back to Citation 42.  Average number of ERISA plans per pre-approved plan = 531,872/1,813 = 293.4. Estimate of total number of ERISA plans filing as part of a DCG = (2 × 71 = 142) × 293.4*0.5 ≉ 20,827. Back to Citation 43.
  11. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    …esulted in a minimum penalty of $2,259 (rounded to the nearest dollar) and a maximum penalty of $11,293 (rounded to the nearest dollar). The amount of the increase from existing § 702.271(a)(2)'s $1,100 minimum penalty to $2,259 is $1,159, which is less than the statutory cap of 150 percent of the existing $1,100 minim…
  12. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    …nk v . Commissioner , 369 U .S . 672, 686 (1962) ; Maadalin v . Commissioner ,' -T .C . Memo . 2008-293 n .7 . - .10 - Minors Act is treated as held by the disabled person or child . Petitioner's other argument is that an IRA is a grantor trust that qualifies as an S corporation shareholder under section 1361(c)(2)(A)(…
  13. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  14. Treas. Reg. § 1.415(b)-1(a)(5)(iv) — Limitations for defined benefit plans.
    IRCRegulationsSep 9, 2016
    … B, when the age-adjusted section 415(b)(1)(A) dollar limit for benefits commencing at that age is $293,453. (ii) Conclusion.
  15. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
  16. T.C. Memo. 2004-11 — Graceann Berry v. Commissioner
    IRCCourt RulingsJan 12, 2004
    …es deductions for such taxable year).” Respondent did not question petitioner’s claim that - 4 - $3,293.20 of the $6,700.00 distribution was for qualified medical expenses and was an exception to the 10-percent additional tax due to early distribution. In that regard, petitioner claimed a standard deduction of $4,300 o…
  17. 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…
  18. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …ities in response to the copayment changes, ranging from -0.11 to -0.14 for these three conditions.[293] Applying these elasticities to the estimated number of self-insured and level-funded group health plan participants and beneficiaries prescribed these ( printed page 4394) medications and assuming a one percent decr…
  19. 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…
  20. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    ess doctrine, courts may invalidate laws if "'men of common intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor - - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945 F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra addresses tran…