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92 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    did not consider the precedential effect of Beech Trucking Co. v. Commissioner, 118 T.C. 428 (2002) (Beech Trucking Co.), and (b) the factors used in determining whether a person is an employer or an employee24 that the Court applied in Transport Labor I were inconsistent with the common-law employment factors applied…
  2. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner, 134 T.C. 280, 294-296 (2010) (discussing the IRM provision that addresses the Commissioner's ability to levy upon retirement accounts). Petitioners wrote "[c]ollection will cause a hardship" on their section 6330 hearing request and provided documents supporting this claim. Settlement Officer Degiovanni …
  3. ERISARegulationsJan 1, 2017★ strong match
    [Reserved]
  4. Rev. Proc. 2015-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 2, 2015
    …ERMINATION LETTERS ARE ISSUED 206 .01 Requesting Determination Letters 206 .02 Forms 206 .03 Timing 207 .04 Application must include copy of plan and amendments 207 .05 Restatements required 207 .06 Controlled groups elections pursuant to Revenue Procedure 2007–44 207 .07 § 414(x) combined plans 207 SECTION 8. EMPLOYER…
  5. 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…
  6. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    cise Tax Regs. Mr. Medina's assignment to the plan of future sales proceeds did - 8 - not result in the repayment of principal or interest. Therefore, petitioners did not correct the prohibited transaction, and the taxable period ended on June 25, 1997, the date respondent mailed the notice of deficiency. Accordingly, …
  7. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    … 5307 filing procedures 206 .03 Additional information with respect to ESOPS submitted on Form 5307 207 .04 Deviations from language of approved plan 207 .05 Adoption of plan prior to date of plan’s letter 207 .06 Timing of determination letter applications for adopting employers of pre-approved plans 207
  8. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    laid out in 18 U.S.C. 207(b), 207(c), and 207(e). Under 18 U.S.C. 207(b), 207(c), and 207(e), former officers or employees of the executive branch, including independent agencies, are prohibited from aiding or advising on matters with which they were involved while in the executive branch for 1 year. These interim fina…
  9. 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…
  10. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    ublication of revenue ruling, etc. 207 .04 Effect of subsequent amendment by employer 207 .05 Revocation or modification of a determination letter 207 .06 Determination letter revoked or modified based on material change in facts applied retroactively 207 .07 Not otherwise generally revoked or modified retroactively 20…
  11. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
  12. 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
    n applied to a particular transaction 207 .08 Retroactive effect of revocation or modification applied to a continuing action or series of actions 207 .09 May be retroactively revoked or modified if the transaction is completed without reliance on the letter ruling 207 .10 Taxpayer may request that retroactivity be lim…
  13. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …best judgment in offering investment opportunities to relevant plan participants and beneficiaries.[207]
  14. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    … MERGER, CONSOLIDATION, ETC.? 206 .01 Scope 206 .02 Required forms 206 .03 Supplemental information 207 .04 Compliance with Title IV of ERISA 207 .05 Termination prior to time for amending for change in law 207 .06 Restatement not required for terminating plan 207 SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PR…
  15. 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…
  16. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …additional conferences 206 .06 Requires written confirmation of information presented at conference 207 .07 May schedule a pre-submission conference 207 .08 Under limited circumstances, may schedule a conference to be held by telephone 207 SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE? 207 .01 Has same effect as a …
  17. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  18. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …0.023 per GB for the first 50 TB, $0.022 per GB for the next 450 TB, and $0.021 per GB beyond that,[207]
  19. Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 4, 2016
    …NT PROCEDURES? 206 .01 Tax Exempt and Government Entities 206 .02 Chief Counsel’s revenue procedure 207 SECTION 5. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER? 207 .01 Scope of this section 207 .02 Scope of determination letters 207 .03 Design-based safe harbor 207 .04 Governmental plans under § 414(d) 208 .05 …
  20. 76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner
    IRCCourt RulingsMar 17, 1981related by meaning
    es not meet the requirements of section 401(a). Accordingly, we need not consider the State law question. Decision nñll be entered for the respondent. This plan was entitled the “Third Amendment to the Miller & Kearney Stock Bonus Plan and Trust” which amended and restated petitioner’s original plan in its entirety. Mo…