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88 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    … financially or its effect on the self-insured group health ( printed page 4377) plan participants.[171] This lack of transparency limits self-insured group health plans' ability to assess the reasonableness of the changes, which can result in unintended consequences for plan participants. Rebates received by self-insu…
  2. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996★ strong match
    … over to an Individual Retirement Account established for the benefit of Mr. Souris. The remaining $171,476 was ineligible to be rolled over, and appears to be attributable to overfunding the plan over the years due to what turned out to be erroneous actuarial assumptions. Thus, as stipulated by the parties, that $171,…
  3. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    50,854 100.0 32,650,854 0.20 6,530,171 Third Year 32,650,854 100.0 32,650,854 0.20 6,530,171 Three-Year Average 44,478,847 44,478,847 $8,895,769 Note: *In the first year, the opt-out notifications are assumed to be sent to all participants. The Department estimates that there are 68,134,832 policyholders between the ag…
  4. 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
    …. [Page 10] On February 23, 1987, Respondent SA executed a second promissory note in the amount of $171,000.00 in favor of Brighton Bank (hereinafter "Loan No. 25-20148-4") and purchased CD No. 350 in the amount of $171,000.00; CD No. 350 was pledged as collateral for this loan.7 Exs. C20, C21 & C22. CD No. 350 was iss…
  5. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …ts of these proposed rules as required by Executive Order 12866, “Regulatory Planning and Review;” [171] Executive Order 13132, “Federalism;” [172] Executive Order 13563, “Improving Regulation and Regulatory Review”; [173] Executive Order 14192, “Unleashing Prosperity Through Deregulation”; [174] the Regulatory Flexibi…
  6. 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…
  7. 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…
  8. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    … approximately 1 hour, incurring a total annual cost for all issuers of approximately $0.2 million.[171] The Departments estimate that approximately 25.5 million paper notices would be sent to eligible employees each year at an annual cost of approximately $1.3 million to produce the notices.[172 173] 4. Increased Heal…
  9. Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of …
    IRCRevenue ProceduresModified Dec 29, 2025
    …s related to Appeals review 170 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2025-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2025-4 171 PART I. GENERALLY APPLICABLE PROCEDURES SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS? 171 .01 In general 171 …
  10. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  11. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ased employees 170 .09 Partial terminations 170 .10 Publication 794, Favorable Determination Letter 171 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 171 .01 Scope 171 .02 Complete information required 171 .03 Complete copy of plan and trust instrument and applicable amendments require…
  12. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …ir. 1990) (internal citation omitted); see also Reetz v. Aon Hewitt Inv. Consulting, Inc., 74 F.4th 171, 182 (4th Cir. 2023) (“Prudence does not mean clairvoyance.”). 2.4.3. The Duty of Prudence Does Not Contain Categorical Restrictions on Investments The same principles of prudence apply to any investment decision, re…
  13. 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…
  14. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    … revenue procedure 164 .03 Other guidance affecting this revenue procedure 165 .04 Updated annually 171 .05 Possible future updates related to Appeals review 171 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2024-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2024-4 171 PART I. GENERALLY …
  15. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  16. 50 T.C. 583 — Audrey Realty, Inc. v. Commissioner
    IRCCourt RulingsJul 18, 1968related by meaning
    62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963). In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
  17. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    … revenue procedure 167 .03 Other guidance affecting this revenue procedure 167 .04 Updated annually 171 .05 Possible future updates related to Appeals review 171 SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2021-4? 171 .01 In general 171 .02 Changes made to Revenue Procedure 2021-4 172 PART I. GENERALLY …
  18. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  19. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    Commissioner , 83 T.C. 755, 791 n.28 (1984); Kahler v. Commissioner , 18 T.C. 31, 34-35 (1952); Roberts v. Commissioner , T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not subject to substantial limitations, and petitioner makes no contention otherwise. Consequently, we find…
  20. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    …mination letter 169 .05 Opinion letter 169 .06 Oral advice 170 .07 Nonbank trustee approval letters 171 .08 Compliance statement 171 .09 Advisory letter 171 SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE? 171 SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT…