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1. 81 FR 80608 — Department of the Treasury Acquisition Regulations; Incremental Funding of Fixed-Price, Time-and-Material or Labor-Hour Contracts During a Continuing Resolution
   IRCFinal Rules (FR)Nov 16, 2016
   remental funding during a Continuing Resolution. 1032.770-1 Scope of section. 1032.770-2 Definition. 1032.770-3 General. 1032.770-4 Policy. 1032.770-5 Limitations. 1032.770-6 Procedures. 1032.770-7 Clause. Subpart 1032.7—Contract Funding 1032.770 Incremental funding during a Continuing Resolution. 1032.770-1 Scope of s…
2. 81 FR 45118 — Department of the Treasury Acquisition Regulations; Incremental Funding of Fixed-Price, Time-and-Material or Labor-Hour Contracts During a Continuing Resolution
   IRCProposed Rules (FR)Proposed Jul 12, 2016
   …ity: 41 U.S.C. 1707. 2. Add subpart 1032.7 to read as follows: Subpart 1032.7—Contract Funding 1032.770 Incremental funding during a Continuing Resolution. 1032.770-1 Scope of section. 1032.770-2 Definition. 1032.770-3 General. 1032.770-4 Policy. 1032.770-5 Limitations. 1032.770-6 Procedures. 1032.770-7 Clause. Subpart…
3. 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…
4. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
   ERISAProposed Rules (FR)Proposed Feb 25, 2026
   …iders) 3,552 Service Providers 1 $181.06 3,552 $643,125 Explanation Preparation (In-House) 77,012 = 770,117 Plans × 10% Not Using a Service Provider 1 181.06 77,012 13,943,731 Adding Contact and Plan Information to Drafted Explanations 693,105 = 770,117 Plans × 90% Using a Service Provider 5/60 70.29 57,759 4,059,862 T…
5. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
   IRCCourt RulingsJan 30, 1958related by meaning
   t it was final and conclusive and not to be reopened except “upon a showing of fraud or malfeasance or a wilful misrepresentation of a material fact.” In view of the foregoing we conclude that the separate identity of the petitioner and the other two corporations must be recognized in these rebate proceedings. Section …
6. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
   ERISACourt RulingsJan 20, 1998
   … Smith loan.15 Ex. C47, C49, C50 & C48. On September 15, 1989, CD No. 11813-18225 was redeemed for $770,892.12 and the proceeds were deposited in Plan's account. Ex. C52 & C53. 2. Secondary Transactions a. Respondent's Use of $100,000.00 On December 9, 1988, SA used $100,000.00 from the Plan's premium transfer account …
7. Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t)
   IRCNoticesJul 8, 2024related by meaning
   nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code. VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
8. 29 T.C. 632 — General Retail Corp. v. Commissioner
   IRCCourt RulingsDec 31, 1957related by meaning
   y its shareholders, partners, or beneficiaries. Sec. 430 (e) (1). As stipulated. Sec. 430 (e) (2) (B). Sec. 430 (e) (2) (B) (1). Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
9. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
   IRCCourt RulingsSep 29, 2009
   … is entitled to no greater weight ."), affd . in part and revd . in part on other grounds 613 F .2d 770 (9th Cir . 1980) . In affirming that opinion in part, the Court of Appeals concluded that "The Tax Court properly declined to defer . to an unreasonable ruling ." Estate of Lang v . Commissioner , 613 F .2d at 776 . …
10. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
12. 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…
13. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    1984) ( stating that when comments “brought to the attention of the agency nothing which it had not already considered”, the agency need not respond). 2. T hat s ome foreign legal restrictions apply only to payments between related parties Second, petitioner points out that two commentators explained that some foreign …
14. 29 C.F.R. § 4043.23(f)(3)(iii) — Active participant reduction.
    PBGCRegulationsJun 24, 2020
    …nt count is 560, the number that gets compared to the beginning-of-year active participant count is 770 (i.e., 560 + 210 = 770). Because 770 is less than 80 percent of 1,000, an attrition event has occurred and must be reported.
15. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
16. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …-0 - - 0 - - 0 - The Trust paid no benefits in 1988. From 1989 through 1994, the Trust paid $30,420,770 in employer withdrawal benefits 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 $27,6…
17. 88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges
    IRCProposed Rules (FR)Proposed Sep 26, 2023
    and $770 for batched determinations in 2023. As such, for approximately 108,000 single determinations and 24,840 batched determinations annually,[92] if current certified IDR entity fixed fees remained applicable, the Departments estimate that disputing parties would pay approximately $59,292,000 for single determinat…
18. Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of…
    IRCNoticesMay 18, 2026related by meaning
    ic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F…
19. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
20. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…