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1. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
   IRCCourt RulingsSep 30, 1991
   …be decided whether the subject property constituted qualifying employer real property under section 407(d)(4) of ERISA. Section 407(d)(4) of ERISA defines “qualifying employer real property” as parcels of “employer real property” if a substantial number of parcels are dispersed geographically. In addition, each parcel …
2. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
   IRCCourt RulingsJun 1, 1987
   …ease transactions did not concern “qualifying employer real property” within the meaning of section 407(d)(4) of ERISA. Petitioners’ assertion is conditioned upon the determination as to whether the subject lease transactions concern “employer real property” within the meaning of section 407(d)(2) of ERISA and, if so, …
3. PLR 200109010 — Sale/Exchange
   IRCPrivate Letter RulingsMar 2, 2001
   …ed person. ERISA §408(e), in turn, cites the definition of qualifying employer securities in ERISA §407(d)(5). Bas ed upon these provisions, the Department of Labor has concluded, and we concur, that for purposes of meeting the exemption under §4975(d)(13) the definition of “qualif ying employer securities” in §407(d)(…
4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
5. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
   IRCCourt RulingsDec 19, 2000★ strong match
   …res set forth in sections 6221 through 6231; i.e., the TEFRA partnership provisions. See TEFRA sec. 407(a)(1), 96 Stat. 670. Under TEFRA section 407(a)(3), 96 Stat. 670, the TEFRA procedures may also apply to partnership taxable years beginning before the September 3, 1982, effective date. TEFRA section 407(a)(3) provi…
6. 85 FR 72846 — Financial Factors in Selecting Plan Investments
   ERISAFinal Rules (FR)Nov 13, 2020
   …entical investments as a “unicorn”). Back to Citation 104.  The Department estimated that there are 407,383 DC plans with QDIAs and that 0.1 percent, or 407 plans, will need to reconsider their QDIAs as a result of the rule. The burden is estimated as follows: (407,383 plans * 0.001 * 20 hours) = 814 hours. A labor rat…
7. 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…
8. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
   IRCCourt RulingsJan 14, 2013related by meaning
   Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
9. Treas. Reg. § 1.407-1(c)(1)(ii) — Treatment of certain employees of domestic subsidiaries engaged in business outside the United States as employees of the domestic parent corporation.
   IRCRegulationsMay 18, 2016
   … (including individuals treated as employees of the domestic parent corporation pursuant to section 407 and this section). (c)(2) (2) Determination of compensation. For purposes of applying section 401(a) (5) and the regulations thereunder, relating to classifications that will not be considered discriminatory, with re…
10. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
11. 29 C.F.R. § 4044.30 — [Reserved]
    PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
12. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979related by meaning
    petitioner sought to deduct, as the sole shareholder, the entire net operating loss of $16,946.11 for the initial short taxable year on his Form 1040. We held in Bianchi that the contribution, including the compensation paid to petitioner during the initial 7-day taxable year, was unreasonable and properly disallowed, …
13. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
15. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
16. T.C. Summary Opinion 2002-138 — Robert L. & Sara J. Helm v. Commissioner
    IRCCourt RulingsOct 18, 2002
    …s) 14,473.86 19,902.36 Line 15a. Total IRA distributions $85,630.90 --- Line 15b. Taxable amount 21,407.73 [2] 21,407.50 Line 33. Adjusted gross income 43,127.58 48,742.89 1 In 1998, petitioners originally reported $1,016.20 of interest income but actually received only $980. See supra note 2. 2 We note that in 1999 pe…
17. 29 C.F.R. § 2550.407a-1(a) — General rule for the acquisition and holding of employer securities and employer real property.
    ERISARegulationsJan 1, 2017
    (a) (a) In general. Section 407(a)(1) of the Employee Retirement Income Security Act of 1974 (the Act) states that except as otherwise provided in section 407 and section 414 of the Act, a plan may not acquire or hold any employer security which is not a qualifying employer security or any employer real property which …
18. 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…
19. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
20. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016related by meaning
    culating the required reduction in the section 415 dollar limitation. Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the age 45 limits for tax years 2002 through 2006 are correct. III. Petitioner's Liabilit…