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91 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    …9 $9,472. § 1903.15(d)(1) $129,336 $132,598. § 1903.15(d)(2) $129,336 $132,598. § 1903.15(d)(3) $12,934 $13,260. § 1903.15(d)(4) $12,934 $13,260. § 1903.15(d)(5) $12,934 $13,260. § 1903.15(d)(6) $12,934 $13,260. DEPARTMENT OF LABOR Mine Safety and Health Administration Title 30—Mineral Resources PART 100—CRITERIA AND P…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ccord Grajales, 156 T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68, Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional amount” within the meaning of section 6751(c). To implement the foregoing, An order will be issued g…
  5. T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont…
    IRCTreasury DecisionsSep 28, 2015
    …erest rate ($200,000 ÷ 1.0590(6/12) = $194,349), for a total interest-adjusted contribution of $201,934. (iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bal…
  6. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  7. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    …ravel expenses $14,043 Taxes 8,891 Gambling losses-- other miscellaneous deductions 25,000 Total 47,934 - 6 - [*6] On the Form 1040X petitioner claimed that he was a professional gambler with the following Schedule C income and expenses: Schedule C Amount claimed Income: Gross receipts $25,000 Returns 25,000 Gross inco…
  8. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    …erest rate ($200,000 ÷ 1.0590(6/12) = $194,349), for a total interest-adjusted contribution of $201,934.(iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bala…
  9. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    harged on or before the valuation date and those charges are not expected to be refunded, rebated or otherwise reversed at a later date, minus (5) any distributions (including distributions of dividends and dividends held on account), withdrawals, or partial surrenders taken prior to the valuation date. Rev. Proc. 2005…
  10. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    tinued...) - 5 - of the Secretary, and in the same manner as taxes. Sec. 6652(c) (4) (A). Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and demand, the Secretary can collect the tax by levy upon the property belonging to the person, subject to …
  11. 80 FR 54374 — Determination of Minimum Required Pension Contributions
    IRCFinal Rules (FR)Sep 9, 2015
    …erest rate ($200,000 ÷ 1.0590(6/12) = $194,349), for a total interest-adjusted contribution of $201,934. (iii) The present value of the excess contribution for 2017 is based on the net contribution required for that year, which is the minimum required contribution minus the offset for the funding standard carryover bal…
  12. Notice 2016-39 — This notice provides guidance as to whether payments received by an employee from a qualified defined benefit plan during phased retirement are amounts receive…
    IRCNoticesJun 27, 2016
    …ring that period. At the annuity starting date, Employee M has an investment in the contract of $50,934.19 ($50,000 plus $5,000 in additional contributions minus $4,065.81 in recovered basis). Because Employee M is receiving a joint and survivor annuity, the number of anticipated payments is determined under the table …
  13. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCProposed Rules (FR)Proposed Aug 3, 2023
    …s part of the Essential Health Benefits requirements. The Departments estimate that there are 2,134,934 ERISA-covered group health plans with less than 50 participants based on data from the 2021 MEPS-IC and the 2019 County Business Patterns from the Census Bureau. The Departments also estimate that 83 percent of group…
  14. 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
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  15. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017
    …T.C. 1, 12 (1989), af[d, 925 F.2d 348, 353 (9th Cir. 1991); see also Neely v. Commissioner, 85 T.C. 934, 947 - 14 -
  16. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026
    …gible property .” Amazon.com, Inc. & Subs. v. Commissioner, 148 T.C. 108, 150 – 51 (2017) , aff’d , 934 F .3d 976 (9th Cir. 2019) . “ When one participant . . . makes pre-existing intangible property available for purposes of research under a QCSA, that party is deemed to have transferred an interest in such property t…
  17. Treas. Reg. § 1.401(a)(9)-6(m)(4)(i)(B) — Required minimum distributions for defined benefit plans and annuity contracts.
    IRCRegulationsSep 17, 2024
    …balance afterwithdrawal 2028 $1,000,000 $550,000 2029 1 954,545 2 $561,000 3 $555,500 4 $26,606 534,934 2030 909,306 545,633 540,283 26,482 519,151 2031 864,291 529,534 524,342 26,760 502,774 2032 819,740 512,829 507,801 27,177 485,652 2033 775,430 495,365 490,509 27,438 467,927 2034 731,620 477,286 472,606 27,853 449,…
  18. Treas. Reg. § 1.408-4(c)(4) — Treatment of distributions from individual retirement arrangements.
    IRCRegulationsMay 18, 2016
    …1975 ($9,334) reduced by the amount allowable to A as a deduction under section 219 ($1,400), or $7,934. A will include the $7 of the $107 distributed on April 1, 1976, in his gross income for 1976. Further, A will pay an additional income tax of $.70 for 1976 under section 408(f)(1).
  19. 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…
  20. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998
    …ble and ordinarily prudent person would do under the circumstances. Neely v. Commissioner , 85 T.C. 934, 947 (1985). The term "disregard" includes any careless, reckless, or intentional disregard. Sec. 6662(c). However, section 6664(c) provides that no penalty shall be imposed with respect to any portion of an underpay…