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87 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
  2. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
  3. 74 T.C. 1029 — E. F. Higgins & Co. v. Commissioner
    IRCCourt RulingsAug 11, 1980
    …lesser pension contributions in the discrimination area. In Container Service Co. v. United States, 345 F. Supp. 235 (S.D. Ohio 1972), affd. per curiam on other grounds 478 F.2d 770 (6th Cir. 1973), the taxpayer, attempting to prove nondiscrimination, argued that the only employees excluded from its corporate profit-sh…
  4. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    on 482 transfer pricing rules that generally apply in allocating income and deductions among related taxpayers. Second, the FSC provisions effectively lowered the tax rate for qualifying export-related taxable income allocated to the FSC. 22See supra note 4. - 30 - A. Relaxed Transfer Pricing Rules Section 925(a) provi…
  5. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999related by meaning
    penses which are ordinary and necessary and recurring in nature. Respondent relies on Rev. Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring expenses paid by an employer are not deductible under this regulation. We disagree. Our analysis starts at s…
  6. 75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans
    IRCProposed Rules (FR)Proposed Nov 22, 2010
    …before reaching the age at which a Federal Benefit Payment is payable to the individual. Section 29.345 provides the rules for adjustments of Federal Benefit Payments after the initial calculation. Under current section 29.345, cost-of-living increases are applied directly to Federal Benefit Payments. The paragraph is …
  7. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  8. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ies and Procedures: Total 146,328 595,837 662,103 12,041 3,453 321,138 6,906 Per-Entity 80 80 80 80 345 345 345 Retrospective Review: Total 6,043 562,032 12,087 Per-Entity 604 604 604 ( printed page 75971) Total: Total 20,078,016 81,756,286 90,848,839 1,660,214 119,169 11,082,746 238,339 Per-Entity 696 696 696 749 1,67…
  9. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … on employer costs and patients' out-of-pocket costs remain uncertain. These mechanisms are opaque,[345] and the variability in how they are implemented across self-insured group health plans contributes to significant uncertainty about their financial impact on patients. For example, copay clawbacks are difficult to i…
  10. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    345 each. As shown in Table 26, the hour burden associated with OPM requirements is estimated to be approximately 1 hour at an equivalent cost of $69. ( printed page 56074) Table 24—HHS's Annual Burden and Costs Request an Extension of Times Periods for Extenuating Circumstances Starting in 2022 Estimated number of res…
  11. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    IRCCourt RulingsMar 25, 2013
    …ertens, Law of Federal Taxation, sec. 5A.11, at 22 (1998 rev.); see also Smith v. Manning, 189 F.2d 345 (3d Cir. 1951); Sterno Sales Corp. v. United States, 170 Ct. Cl. 506, 345 F.2d 552 (1965); Reynard Corp. v. Commissioner, 30 B.T.A. 451 (1934); Mosby v. Commissioner, T.C. Memo. 1984-90; Zeunen Corp. v. United States…
  12. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  13. 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, 2026
    ….B. 2026-21 1502 Proposed Regulations: Article Issue Link Page REG-101952-24 2026-03 I.R.B. 2026-03 345
  14. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …ty: Unseparated product at $4.99/ton_ $568, 765. 19 $179, 729. 80 $389, 035. 39 Byproduct sales_ 1, 345. 05 1, 345. 05 Less royalties_ 22, 895. 89 7, 235. 10 15, 660. 79 Adjusted gross income_ 547, 214. 35 172, 494. 70 374, 719. 65 Direct costs_ 440, 229. 89 Adm. prorated_ 21, 850. 24 Net income_ 85, 134. 22 50% of net…
  15. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999★ strong match
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  16. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …ent years Activity Burden hours Equivalent burden cost Burden hours Equivalent burden cost Legal 11,345 $1,807,633 0 $0 Total 11,345 1,807,633 0 0 According to Cerulli Associates, in 2022, almost 4.5 million defined contribution (DC) plan accounts with $779 billion in assets were rolled over to an IRA. Additionally, 0.…
  17. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    rences are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are (1) whether a pension plan distribution to petitioner is taxable pursuant to section 402(a)(1) and whether petitioner is liable for a 10-perc…
  18. 87 FR 71164 — Voluntary Fiduciary Correction Program
    ERISAProposed Rules (FR)Proposed Nov 21, 2022
    …otal hour burden associated with the VFCP exemption will be 4,743 hours with an equivalent cost of $345,292. The total cost burden associated with the VFCP exemption will be $66,011. Summary The total aggregate annual hour burden for the information collection arising from the VFC Program and the exemption is estimated…
  19. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    IRCCourt RulingsSep 26, 2001related by meaning
    effect, rewrite the statute to achieve what seems to be a more equitable result. See Eanes v. Commissioner , supra at 171. “Whether and to what - 6 - extent deductions shall be allowed depends upon legislative grace; and only as there is clear provision therefor can any particular deduction be allowed.” New Colonial Ic…
  20. Court of Appeals for the Tenth Circuit — Phillips v. Boilermaker-Blacksmith National Pension Trust
    ERISACourt RulingsSep 29, 2026
    …ual knowledge, not the ability to discover something. Id. at 186; see also Su v. Johnson , 68 F.4th 345, 356 – 57 (7th Cir. 2023) (concluding that disclosure of a