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Go to 48 T.C. 773 (not yet in the library — opens the official source)
71 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 69 T.C. 773 — Lansons, Inc. v. Commissioner
    IRCCourt RulingsFeb 27, 1978
    Drennen, Judge: Respondent determined deficiencies in Federal income tax as follows: Docket No. Petitioner FYE Aug. Sl-Deficiency 9336-74 Lansons, Inc. .1969 $7,509.58 1970 8,546.65 1971 10,035.19 9347-74 Lansons, Inc., Profit-Sharing Trust: Louis Levine and A. J. Kaiser, trustees. 1971 165.87 One issue in docket No. 9…
  2. 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…
  3. 103 T.C. 200; 103 T.C. No. 13 — Rubin v. Commissioner
    IRCCourt RulingsAug 15, 1994
    …g the income tax deduction by the corporation for the year ended June 30, 1988 in the amount of $56,773.00 because your firm filed a form 5500-C and only claimed a payment of $20,000.00, not $36,773.00. The total contribution for the year ended June 30, 1988 was $56,773.00 and was based upon telephone advice that I rec…
  4. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …otal of the funding standard carryover balance and prefunding balance as of January 1, 2011, is $68,773. Example 3.(i) The facts are the same as in Example 1, except that Sponsor S contributes $90,539 to Plan P on February 1, 2011, for the 2010 plan year and makes no other contributions to Plan P for the 2010 plan year…
  5. Treas. Reg. § 54.4975-14(a) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. Section 2003(c)(1)(B) of the Employee Retirement Income Security Act of 1974 (88 Stat. 978) provides an election to pay an excise tax by certain persons involved prior to 1975 in prohibited transactions within the meaning of section 503 (b) or (g).
  6. 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…
  7. 88 FR 56563 — Valuation Assumptions and Methods
    PBGCProposed Rules (FR)Proposed Aug 18, 2023
    …445 3,445 2029 834 834 3,524 3,524 2030 854 854 3,605 3,605 2031 873 873 3,688 3,688 2032 893 893 3,773 3,773 2033 or later 914 914 3,860 3,860 1
  8. 89 FR 58644 — Required Minimum Distributions+
    IRCProposed Rules (FR)Proposed Jul 19, 2024
    … the hypothetical required minimum distribution for 2031 (the year in which B reaches age 73) is $3,773.58 ($100,000.00/26.5). For 2032 (the year in which B reaches age 74), the adjusted account balance is calculated by reducing the $100,000.00 account balance by the excess of the hypothetical required minimum distribu…
  9. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    erest) on the dates shown was as follows: Bate Balance 8/31/78 $123,727.08 8/31/79 131,211.18 8/31/80 141,708.07 8/31/81 144,502.33 4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
  10. 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…
  11. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …review the district court’s grant of summary judgment de novo. Harrison v. Wells Fargo Bank, N.A. , 773 F.3d 15, 20 (4th Cir. 2014). But we apply the same standards employed by the district court in considering the plan administrator’s decision. Id.
  12. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    …50,783,404.03 Employee contributions -0- $ 1,555,626.86 1,841,554.51 2,505,955.35 Interest earned 3 773.98 1,749,030.80 78,641.10 -0Benefits paid -0- 39,153,640.83 48,808,587.03 53,289,359.38 Ending balance 42,000,773.98 6,151,016.83 -0- -01 Represents the total of petitioner’s monthly contributions to the VEBA Trust. …
  13. 50 T.C. 384 — Ed & Jim Fleitz, Inc. v. Commissioner
    IRCCourt RulingsMay 27, 1968related by meaning
    404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60. All Code references herein are to the Internal Revenue Code of 1954. Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
  14. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976★ strong match
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
  15. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    …review the district court’s grant of summary judgment de novo. Harrison v. Wells Fargo Bank, N.A. , 773 F.3d 15, 20 (4th Cir. 2014). But we apply the same standards employed by the district court in considering the plan administrator’s decision. Id.
  16. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …he statement in the first year. This results in a burden of 4,678 hours with an equivalent cost of $773,313 in the first year.[85] Table 5—Hour Burden and Equivalent Cost Associated With the Written Statement of the Best Interest Standard of Care Owed Activity Year 1 Subsequent years Burden hours Equivalent burden cost…
  17. 87 FR 74968 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 7, 2022
    …445 3,445 2029 834 834 3,524 3,524 2030 854 854 3,605 3,605 2031 873 873 3,688 3,688 2032 893 893 3,773 3,773 2033 or later 914 914 3,860 3,860 1 Applicable tables for valuation dates before 2023 are available on PBGC's website ( www.pbgc.gov). 2 Table II-A. 3 Table II-B. 4 Table II-C. * * * * * Issued in Washington, D…
  18. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  19. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    or lack of jurisdiction. Appropriate orders will be issued. Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
  20. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…